A.M. No. P-20-4050, June 14, 2022
Presiding Judge Alejandro Ramon C. Alano, Branch 55, Regional Trial Court, General Santos City, South Cotabato, Complainant, vs. Ruel V. Delicana, Legal Researcher I, Branch 3, Municipal Trial Court in Cities, General Santos City, South Cotabato, Respondent. [OCA IPI No. 16-4578-RTJ] Ruel V. Delicana, Complainant, vs. Judge Alejandro Ramon C. Alano and Mary Jane G. Corpuz, Sheriff III, Respondents.

FACTS

These are consolidated administrative complaints filed reciprocally by Judge Alejandro Ramon C. Alano and court employee Ruel V. Delicana. Delicana, a Legal Researcher at MTCC Branch 3, filed a complaint against Judge Alano (his former Presiding Judge) and Sheriff Mary Jane G. Corpuz. He alleged Grave Misconduct, Abuse of Authority, and Conduct Prejudicial to the Service. His core grievance stemmed from Judge Alano’s July 2015 memorandum designating Corpuz, not him, as Acting Clerk of Court. In that capacity, Corpuz rated Delicana’s performance as merely “satisfactory,” which he claimed was the lowest in his 16-year career, given out of personal vendetta and without due process. He further accused Judge Alano of various improprieties, including neglect of duty and making derogatory remarks.
In his counter-complaint, Judge Alano accused Delicana of Gross Insubordination, Conduct Unbecoming, and using intemperate, offensive, and abusive language in his pleadings and communications. He detailed Delicana’s history of disrespectful behavior, including filing numerous administrative cases against colleagues and superiors, and submitting pleadings containing insulting and scandalous accusations that undermined judicial authority and the court’s integrity.

ISSUE

The central issue is whether the respondents are administratively liable for their respective acts as alleged in the reciprocal complaints.

RULING

The Court found respondent Ruel V. Delicana GUILTY of Gross Insubordination and Conduct Prejudicial to the Best Interest of the Service, and imposed the penalty of DISMISSAL. The complaints against Judge Alano and Sheriff Corpuz were DISMISSED for lack of merit.
The legal logic hinges on the standard of conduct required of all judiciary personnel and the gravity of insubordination. The Court emphasized that court employees must act with propriety and decorum to preserve public confidence in the judiciary. Delicana’s actions constituted a clear pattern of gross insubordination. His use of intemperate, offensive, and scandalous language in official pleadings—referring to a judge as “incompetent” and making baseless accusations of corruption—was a direct assault on judicial authority and the administration of justice. Such behavior is intrinsically prejudicial to the service. The Court distinguished between a mere heated exchange and a sustained campaign of disrespect, finding the latter in Delicana’s conduct. His prior administrative record, where he was previously suspended for similar conduct, established him as a recidivist, warranting a severe penalty.
Regarding Delicana’s charges, the Court found them unsubstantiated. Judge Alano’s discretionary act of designating Corpuz as Acting Clerk of Court was within his administrative prerogative. The performance rating, while dissatisfying to Delicana, was not proven to be malicious or irregular. Other allegations, like improper overtime or kitchen use, were minor and did not constitute serious administrative offenses. The dismissal of the case against Judge Alano and Corpuz underscores that administrative complaints must be supported by substantial evidence, not mere speculation or personal grievance. The paramount consideration is the preservation of the judiciary’s integrity, which Delicana’s actions severely threatened, justifying