A.M. No. P-06-2252. July 9, 2007. VIRGINIA D. SEANGIO, Complainant, vs. JULIETA F. PARCE, Court Stenographer III, Regional Trial Court, Branch 36, Manila, Respondent.
FACTS

Virginia D. Seangio, administratrix of an estate, filed a complaint against Court Stenographer Julieta F. Parce for Conduct Unbecoming a Court Personnel. The complaint arose from Parce’s preparation of the transcripts of stenographic notes (TSN) for hearings on August 25 and September 5, 2005, where Seangio testified. Complainant alleged undue delay in the TSN’s submission and serious discrepancies between the transcript and the actual testimony, including missing pages, misattributed statements, and disorganized page sequences. A court-ordered review of the tape recordings confirmed the TSN was not in proper order. It was also discovered that the tape for an April 29, 2005 hearing was no longer available, as respondent had reused it for another case.
In her defense, respondent attributed the pagination errors and delays to her heavy workload and the voluminous nature of the notes. She claimed the missing page was a numbering error and that no testimony was omitted. She justified reusing tapes due to economic reasons, stating the Supreme Court does not provide free blank tapes. She also asserted it was not her practice to submit untranscribed notes to the court.

ISSUE

Whether respondent Julieta F. Parce is administratively liable for the errors in the TSN, the delay in its submission, and the reuse of the tape recording.

RULING

Yes, but for Simple Neglect of Duty, not Conduct Unbecoming. The Court emphasized the indispensable role of stenographers in the judicial process and the necessity for accuracy and diligence in recording proceedings. While the evidence did not establish that respondent deliberately falsified the TSN, her actions constituted negligence. The disorganized transcription, failure to preserve the original tape recording for the April 29 hearing, and delay in submission fell short of the required standard of care. The Court cited Section 17, Rule 136 of the Rules of Court, which mandates stenographers to deliver their notes to the clerk of court immediately after each session for attachment to the record, a duty respondent admitted not following. Her reuse of the tape, thereby erasing a prior official recording, was a clear dereliction. The Court found the Office of the Court Administrator’s evaluation sound, holding that these lapses, while not malicious, amounted to Simple Neglect of Duty, defined as the failure to give proper attention to a task expected of an employee. The penalty was a fine of Two Thousand Pesos (₱2,000.00) with a stern warning.