G.R. No.: A.M. No. P-11-3020 (Formerly OCA LP.I. No. 10-3525-P)
Date: June 25, 2014

Case Parties:
Presiding Judge Juan Gabriel Hizon Alano, Mary Annabelle A. Katipunan, Suzee Wong Jamotillo, Analie Del Rio Balitung, Edwino Jayson Oliveros, and Roberto Babao Dofio, Complainants, vs. Padma Latip Sahi, Court Interpreter I, Municipal Circuit Trial Court (MCTC), Maluso, Basilan, Respondent.

FACTS

The complainants, staff of the 2nd MCTC, Maluso, Basilan, filed a verified complaint against respondent Padma Latip Sahi, Court Interpreter I of the same court, for Gross Inefficiency, Gross Insubordination, and for being Notoriously Undesirable. Presiding Judge Juan Gabriel Hizon Alano alleged that from his assumption of office in February 2004, respondent was grossly inefficient, failing to prepare court calendars or minutes of proceedings, tasks which were instead performed by complainant Mary Annabelle Katipunan. Respondent was also accused of not knowing the necessary Yakan and Visayan dialects, requiring the judge to interpret testimonies. She received consecutive unsatisfactory performance ratings in 2008. Despite a Court order in March 2010 directing her to return to her official station after a detail, she did not report for over a month, and her Daily Time Records from August 2009 to May 2010 were unsigned by authorized persons. Specific instances of inefficiency included an error-filled court calendar prepared for July 29, 2010, and a failure to prepare and post a calendar for September 16, 2010, causing confusion. Due to her stubborn refusal to perform duties, Judge Alano relieved her and designated other staff as acting interpreters. Complainants also alleged she abused her position by requiring colleagues to fill out incorrect tax returns and prepare promissory notes for litigants, and that she was notoriously undesirable, acting with indifference and falsely implicating colleagues.
In her Comment, respondent Sahi denied the charges, claiming they were malicious lies concocted by Judge Alano in retaliation for her earlier filing of a complaint against him. She refuted the claim about not knowing dialects, asserted her performance ratings were unfairly given due to the judge’s dislike, and alleged unfair treatment caused her to suffer a stroke, leading to her resignation in January 2011.

ISSUE

Whether respondent Padma Latip Sahi is administratively liable for inefficiency and incompetence in the performance of her official duties.

RULING

Yes, respondent Padma Latip Sahi is administratively liable for inefficiency and incompetence. The Court agreed with the Office of the Court Administrator’s (OCA) findings and recommendation. The charges were proven by corroborating testimonies and documentary evidence, including her failure to promptly report to her official station as directed, her unsigned Daily Time Records, her preparation of error-filled court calendars that caused confusion and delay, her failure to prepare and post calendars, and her consistent unsatisfactory performance ratings despite being called to correct her errors. Her general denial and uncorroborated allegations of retaliation were deemed self-serving and insufficient to counter the specific, evidence-backed charges. The Court emphasized that court personnel must perform their duties with utmost responsibility and competence, as they are integral to the public’s perception of the judiciary.
Respondent’s resignation during the pendency of the case did not render it moot, as resignation is not an escape from administrative liability. Considering the circumstances—including her resignation, poor health, and the delay in processing her separation benefits—the Court modified the applicable penalty under the Revised Rules on Administrative Cases in the Civil Service. Instead of suspension, she was meted a fine equivalent to two months’ salary, to be paid within 30 days from receipt of the Decision.