G.R. No. A.M. No. P-18-3796. January 22, 2018. ATTY. MA. JASMINE P. LOOD, MARY JANE G. CORPUZ, AND MA. HAZEL P. SEBIAL, Complainants, v. RUEL V. DELICANA, LEGAL RESEARCHER, BRANCH 3, MUNICIPAL TRIAL COURT IN CITIES [MTCC], GENERAL SANTOS CITY, SOUTH COTABATO, Respondent.
FACTS:

This administrative case originated from a letter written by respondent Ruel V. Delicana, a Legal Researcher at MTCC, Branch 3, General Santos City, to his Executive Judge. In the letter, he protested the designation of Mary Jane Ganer-Corpuz, a Sheriff III from the Office of the Clerk of Court, as the Acting Clerk of Court for his branch. Delicana argued the designation violated a prior office agreement to select an acting clerk from within the branch staff and claimed Ganer-Corpuz could not be impartial due to a prior administrative complaint he had filed against her.
Subsequently, Ganer-Corpuz, along with Atty. Ma. Jasmine P. Lood and Ma. Hazel P. Sebial, filed a complaint against Delicana for Conduct Prejudicial to the Best Interest of the Service. They alleged that Delicana had widely disseminated copies of his protest letter, the attached administrative complaint, and confidential office minutes to numerous external parties, including other judges, prosecutors, local government officials, and bar association officers. Complainants asserted this dissemination of internal matters to unrelated offices was libelous and scandalous.

ISSUE

Whether respondent Ruel V. Delicana is administratively liable for his actions in disseminating the complaint and internal documents to various external offices and individuals.

RULING

Yes, the respondent is administratively liable. The Court found that Delicana’s act of widely circulating his letter and the attached documents to parties outside the normal official channels constituted simple misconduct. While employees have the right to air grievances, this must be done through proper avenues and with due regard for the confidentiality of internal matters. By distributing the documents to a broad array of external recipients, including local politicians and bar officials who had no official role in resolving the internal personnel dispute, Delicana acted improperly. His conduct unnecessarily exposed the complainants to public scrutiny and distrust, thereby tarnishing the court’s image and diminishing public confidence in the judiciary. This behavior fell short of the high standards of conduct required of court personnel.
The Court emphasized that the withdrawal of the complaint by one of the complainants does not divest it of jurisdiction to discipline erring court employees, as administrative cases involve public interest. Considering Delicana’s previous administrative sanction and the presence of mitigating factors—including his 17 years of service and reconciliation with a complainant—the Court modified the penalty. Instead of dismissal, which is prescribed for a second offense of simple misconduct, the Court imposed a one-year suspension without pay, with a stern warning against repetition.