G.R. No. A.M. P-16-3616, June 21, 2017
Atty. Prosencio D. Jaso, Complainant vs. Gloria L. Londres, Court Stenographer III, Regional Trial Court, Branch 258, Parañaque City, Respondent

FACTS

Complainant Atty. Prosencio D. Jaso, a practicing lawyer with a pending case before RTC Branch 258 in Parañaque City, alleged that respondent Gloria L. Londres, a Court Stenographer III in the same branch, approached him in November 2013 to borrow PHP 100,000.00 for her application with the LTFRB. Atty. Jaso lent the amount on November 27, 2013, upon Londres’ execution of a promissory note and issuance of a postdated check. Before the check’s due date, Londres requested not to deposit it due to insufficient funds and promised cash payment instead. Despite repeated demands over the ensuing years, Londres failed to fully settle the debt.
In her defense, Londres admitted borrowing the money but denied using her official position to secure the loan. She claimed she had made partial payments, as evidenced by deposit slips, and attributed her failure to pay in full to financial difficulties caused by the illnesses and subsequent deaths of her sister-in-law and father. The Office of the Court Administrator (OCA) found her administratively liable.

ISSUE

Whether respondent Gloria L. Londres is administratively liable for her failure to pay her debt to Atty. Jaso.

RULING

Yes, the Supreme Court found respondent guilty of conduct prejudicial to the best interest of the service. The legal logic is anchored on the principle that court personnel must uphold the judiciary’s integrity in both official and personal conduct. Willful failure to pay a just debt is a ground for administrative sanction, as it erodes public trust in the judiciary. While Londres’ financial troubles were acknowledged, the Court ruled that such difficulties do not excuse the prolonged non-payment of a lawful obligation.
The Court emphasized that Londres’ transaction with Atty. Jaso, a lawyer with business before her court, created a situation that could impair the court’s image. Although it was not conclusively proven that she exploited her position to obtain the loan, her actions fell short of the high ethical standards required of court employees. Under the Revised Rules on Administrative Cases in the Civil Service, willful failure to pay just debts is a light offense. Considering it was her first offense and the absence of clear evidence of leveraging her position, the Court modified the OCA’s recommendation and imposed a one-month suspension with a stern warning. She was also ordered to pay her outstanding debt immediately.