AM P 09 2677; (March, 2011) (Digest)
G.R. No.: A.M. No. P-09-2677; March 9, 2011 (Formerly OCA I.P.I. No. 07-2582-P)
Case Parties/Title: ANGELINA C. LIM and VIVIAN M. GADUANG, Complainants, vs. MARIBETH G. AROMIN, Records Officer I, Office of the Clerk of Court, Municipal Trial Court, Meycauayan, Bulacan, Respondent.
FACTS
Complainants Angelina C. Lim and Vivian M. Gaduang filed a joint affidavit complaint against respondent Maribeth G. Aromin, a Records Officer I at the MTC of Meycauayan, Bulacan, for alleged violations of R.A. 6713 (Code of Ethical Standards for Public Officials and Employees) in relation to NLRC Case No. RAB-III-03-7148-04. Complainants alleged that on November 8, 2006, while they were at the warehouse of Holland Industries in Meycauayan, Bulacan, to load properties acquired by virtue of a final NLRC Decision, Alias Writ of Execution, and Certificate of Sheriff’s Sale, respondent Aromin arrived. Aromin ordered them to stop loading, claiming someone would bring a court order to halt the sale’s implementation. After an hour with no one arriving, complainants proceeded, at which point Aromin allegedly shouted invectives at them. Complainants questioned Aromin’s presence at the warehouse during office hours, her misrepresentation as the wife of Reynaldo Lim, and her meddling in their case despite being a court employee.
In her Comment, Aromin denied the accusations. She claimed she was summoned to the warehouse by its owner, Billy Lim, to seek police assistance because complainants were trying to forcibly open it. She stated she merely advised complainant Gaduang to wait for the owner and denied shouting invectives or knowing Angelina Lim personally. She maintained the complaint was harassment because she was a witness in a criminal complaint filed by Billy Lim against the complainants.
Due to conflicting accounts, the Office of the Court Administrator (OCA) referred the case for investigation. The Investigating Executive Judge found the allegation of shouting invectives unproven but concluded Aromin was guilty of improper conduct. The judge found that Aromin, upon request of her friend Billy Lim, used her position as a court employee to interfere with the execution of a court judgment during official working hours without being on leave. The OCA later found Aromin guilty of violating the Code of Conduct for Court Personnel.
ISSUE
Whether respondent Maribeth G. Aromin is administratively liable for her actions on November 8, 2006, which constitute conduct unbecoming a court employee.
RULING
Yes, the Supreme Court found respondent Maribeth G. Aromin GUILTY of violation of Section 1, Canon IV of the Code of Conduct for Court Personnel. The Court adopted the findings and recommendation of the OCA.
The Court emphasized that court personnel must devote official time exclusively to public service and must act with professionalism, as their conduct reflects on the judiciary. It was established that November 8, 2006, was a regular working day, and Aromin admitted she was at the warehouse to help her friend Billy Lim stop the execution of a sheriff’s sale. She was absent from her official duties without leave, and her involvement in a private dispute was not part of her official functions.
More significantly, the Court found Aromin’s interference with the execution of a valid Certificate of Sheriff’s Sale, in behalf of a friend and using her position as a court employee, to be highly improper. Her actions led complainants to believe she was leveraging her official capacity to favor one party over another, despite existing judicial orders. This conduct fell short of the standards required of court personnel, who must uphold public interest over personal interest.
The Court imposed a FINE of ₱5,000.00 on Aromin, with a stern warning that a repetition of similar acts would warrant a more severe penalty. The decision serves as a reminder that judiciary employees must be examples of uprightness in both official and personal conduct to preserve the court’s integrity.
