AM P 16 3418; (August, 2016) (Digest)
A.M. No. P-16-3418. August 8, 2016. OFFICE OF THE COURT ADMINISTRATOR, complainant, vs. ANTONIA P. ESPEJO, STENOGRAPHER III, REGIONAL TRIAL COURT, BRANCH 20, VIGAN CITY, ILOCOS SUR, respondent.
FACTS
This administrative case originated from a letter by Judge Francisco A. Ante, Jr., informing the Office of the Court Administrator (OCA) that the records of LRC Case No. N-026 were missing. The case involved an application for land registration initially filed with the Municipal Trial Court in Cities (MTCC) of Vigan City. After the Court of Appeals reversed the MTCC’s decision and dismissed the application, the appellate court remanded the records to the court of origin. Investigation revealed that the postal service mistakenly delivered the records parcel to the Regional Trial Court, Branch 20 (RTC-Branch 20), where respondent Antonia P. Espejo, a Stenographer III, received and signed for it on March 24, 2008.
When the applicants later inquired about the records, the MTCC Clerk of Court discovered the misdelivery and requested Espejo to produce the records. Espejo failed to comply and later denied receiving them, despite evidence of her signature on the postal registry. In her defense, Espejo claimed she immediately turned over the misdelivered mail to the MTCC Clerk of Court but could not provide any proof of receipt. She also argued she was not the official custodian of the records and had no personal interest in the case.
ISSUE
Whether respondent Antonia P. Espejo is administratively liable for the loss of the court records.
RULING
Yes, the Supreme Court found respondent guilty of Simple Misconduct. The Court agreed with the OCA’s recommendation. It was established that Espejo received the records. Her duty of care did not end upon receipt; she was obligated to exercise diligence, especially knowing the mail was addressed to another court. While not the official custodian, her possession of the records made her responsible for their safekeeping. Her claim of having turned them over was unsubstantiated and lacked credible evidence.
The Court defined misconduct as a transgression of an established rule. For it to be grave, elements like corruption or flagrant disregard must be present. Here, Espejo’s actions constituted simple misconduct—characterized by carelessness and disregard for court records, which caused inconvenience, expense, and delay, thereby reflecting poorly on the judiciary. The fact that the records could be reconstituted did not absolve her liability. Considering her over 30 years of service and that this was her first offense as mitigating circumstances, the Court imposed a fine of Five Thousand Pesos (P5,000.00) with a stern warning.