AM P 06 2151; (August, 2006) (Digest)
A.M. No. P-06-2151, August 28, 2006
Maria Raquel R. Bajar vs. Victoriano P. Baterisna
FACTS
Complainant Maria Raquel R. Bajar, a Records Officer III, filed an administrative complaint against respondent Victoriano P. Baterisna, a Records Officer II, both from the Archives Section of the Manila RTC Clerk of Court’s Office. The complaint stemmed from an incident on June 30, 2003, where Bajar and a visitor found the Bodega room locked from the inside during office hours. After knocking, Baterisna opened the door. Bajar subsequently issued a memorandum reminding him that the room should be open for official use. Baterisna refused to receive it.
Later that afternoon, Baterisna went to Bajar’s office and publicly berated her, making derogatory remarks about her authority, English proficiency, and personal habits. The following day, July 1, 2003, when both were summoned before the Clerk of Court, Atty. Buendia, Baterisna again verbally assaulted Bajar in a loud voice, accusing her of being uneducated, a traitor, and disliked by colleagues, and even made threats.
ISSUE
Whether respondent Victoriano P. Baterisna is administratively liable for his actions towards his superior, complainant Maria Raquel R. Bajar.
RULING
Yes, respondent is administratively liable for Gross Discourtesy in the Conduct of Official Duties. The Supreme Court emphasized that all court personnel must adhere to the highest standards of conduct as outlined in the Code of Conduct and Ethical Standards for Public Officers and Employees ( R.A. No. 6713 ). They are required to act with professionalism, respect, and courtesy to maintain the judiciary’s integrity and public trust.
The Court found Baterisna’s actions—publicly insulting and shouting at his superior on two separate occasions, first in front of her staff and then in the presence of the Clerk of Court—constituted gross discourtesy. His conduct demonstrated a blatant lack of respect for authority and proper office decorum. The Court rejected his defense that the conflict was merely personal, ruling that such hostile behavior during office hours and within court premises directly relates to official duties and tarnishes the court’s image. This behavior falls under a less grave offense under Civil Service Rules. Accordingly, the Court suspended Victoriano P. Baterisna for one month and one day, with a stern warning against repeating such acts.