Juntilla v. Calleja
REITERATIONFacts
The Antecedents: Complainant Anatolia A. Juntilla filed an administrative complaint against Atty. Teresita J. Calleja, Branch Clerk of Court, and Salome A. Montezon, Court Stenographer, for alleged acts grossly prejudicial to her in Special Proceedings Case No. 1353. This underlying case involved Juntilla's petition for letters of administration over her deceased sister's property, which was opposed by the alleged common-law husband who claimed the properties were conjugal assets. The trial court dismissed Juntilla's petition due to her failure to file a formal offer of evidence. Procedural History: Following the dismissal of her petition in Special Proceedings Case No. 1353, Anatolia Juntilla filed a notice of appeal. She subsequently lodged an administrative complaint against the Branch Clerk of Court and the Court Stenographer, alleging they conspired to deliberately not submit stenographic notes in her favor, which she claimed prejudiced her case before the Court of Appeals. The Office of the Court Administrator (OCA) conducted an investigation, making findings on the actions of both respondents. The Petition: The administrative complaint, as processed by the OCA and reviewed by the Supreme Court, focused on the alleged failure of respondent Montezon, the Court Stenographer, to transcribe and submit stenographic notes within the required period, and the alleged failure of respondent Calleja, the Branch Clerk of Court, to ensure compliance and to accurately report the status of the records to the Court of Appeals. The Supreme Court ultimately found both respondents liable, imposing fines and warnings for their respective neglects and derelictions of duty.
Issue(s)
Whether respondent Atty. Teresita J. Calleja, Branch Clerk of Court, is liable for neglect of duty. Whether respondent Salome A. Montezon, Court Stenographer, is liable for dereliction of duty.
Ruling
The Supreme Court found both respondents liable. Atty. Teresita J. Calleja was fined P1,000.00 and admonished for neglect of duty. Salome A. Montezon was fined P3,000.00 for dereliction of duty and warned against repetition.
Ratio Decidendi
On the charge against respondent Atty. Teresita J. Calleja, Branch Clerk of Court: It is the duty of the Clerk of Court to demand that the stenographer comply with their duty to transcribe notes. Atty. Calleja must not only direct the stenographer but also ensure strict compliance with the order. The Clerk of Court is responsible for ensuring an orderly and efficient record management system and supervising personnel under her office, such as the stenographer, to function effectively. The Clerk of Court is an essential officer performing delicate administrative functions vital to the prompt and proper administration of justice. In this case, respondent Clerk of Court was found remiss in her duty when she wrote to the CA stating that the record had been forwarded, despite knowing that Montezon had not yet transcribed the stenographic notes. The failure of the Clerk of Court to transmit the record of a case constitutes negligence warranting disciplinary action. The transmission of the record is the function of the Clerk of Court, not the stenographer, whose role is limited to transcription. Public office is a public trust, and all public officers are accountable to the people at all times. Their duties and responsibilities must be strictly performed, and any omission or act diminishing faith in the Judiciary should be condemned. The Court found her liable for neglect of duty. On the liability of respondent Salome A. Montezon, Court Stenographer: Rule 136, Section 17 of the Rules of Court imposes upon court stenographers the duty to deliver all stenographic notes taken to the Clerk of Court immediately after the session, and transcripts are required to be attached to the records not later than ten (10) days from the time the notes were taken. The records showed that respondent Montezon took stenographic notes on January 31, 1985, November 7, 1985, and March 17, 1987. After more than ten years, these notes remained untranscribed and untransmitted to the Court of Appeals (CA), and the CA decision was promulgated without the transcript of stenographic notes (TSN). This clearly demonstrates Montezon's dismal failure to comply with her public duty to transcribe the notes within the required period, despite Atty. Calleja's order to submit them. As an employee of the judiciary, Montezon is duty-bound to diligently perform her assigned tasks and obey her superiors. Her dereliction of duty, which could jeopardize public faith and confidence in the judicial system, should not be countenanced. The Court found her liable for dereliction of duty.
Main Doctrine
Both the Branch Clerk of Court and the Court Stenographer are liable for neglect of duty and dereliction of duty, respectively, for the failure to timely transcribe and transmit stenographic notes, which resulted in the delay or dismissal of an appeal, thereby diminishing public faith in the judiciary.