Valdez v. Soriano
REITERATIONFacts
The Antecedents: Ferdinand Valdez (Valdez) was a defendant in a civil case for Collection of Sum of Money before the Municipal Circuit Trial Court (MCTC). On April 2, 2013, the MCTC rendered judgment ordering Valdez to pay P16,000.00 plus interest. On August 8, 2013, Valdez went to the MCTC to inquire where to pay. Estrella B. Soriano (Soriano), a Court Stenographer I, convinced Valdez to hand over P16,000.00 as payment for the judgment obligation, issuing an Acknowledgment Receipt. Soriano promised to deliver the payment to the bank. Subsequently, Valdez was summoned by the bank regarding his unpaid obligation, as evidenced by a Certification dated August 7, 2014. Valdez confronted Soriano, who did not provide an adequate explanation. Valdez alleged that his obligation incurred penalties and interests due to Soriano's actions. With the help of Atty. Celerino Jandoc, Valdez recovered his money from Soriano, who then paid the bank P16,000.00 for and in behalf of Valdez's wife, Amelia Valdez, to avoid an administrative case. Procedural History: In her Comment, Soriano denied the allegations, claiming Valdez opted to leave the payment with her as she was the only employee available. She asserted she immediately notified the bank's President and General Manager, Pura C. Romero, who assured her a collector would be sent. Soriano kept the money in a sealed office drawer. She claimed she reminded Romero, who repeatedly assured her of collection. When Atty. Jandoc inquired, Soriano informed him the bank never received the payment despite notices. Out of goodwill, Soriano personally delivered the money to the bank and paid the interests and penalties herself. Valdez, in his Reply, belied Soriano's claim, presenting an Affidavit from Romero stating she was never notified by Soriano about the payment. Valdez emphasized the bank was a walking distance from the court and Soriano only delivered the payment after being threatened with an administrative case. The Petition: The Office of the Court Administrator (OCA) recommended that Soriano be found guilty of simple misconduct and suspended for one month and one day without pay. The OCA found that Soriano received P16,000.00 from Valdez, promising to deliver it to the bank, but kept it for over a year despite the short distance. The OCA noted that accepting money from a litigant is not part of a stenographer's duties and that her actions created an impression of personal benefit, constituting Conduct Prejudicial to the Best Interest of the Public Service. However, considering the acts were not of such gravity as to cause gross prejudice or amount to corruption, the OCA recommended simple misconduct.
Issue(s)
Whether Soriano's act of receiving and failing to promptly deliver the payment for a judgment obligation constitutes Simple Misconduct or Conduct Prejudicial to the Best Interest of the Service. Whether Soriano's actions, as a court stenographer, were within the scope of her official duties.
Ruling
The Court finds Estrella B. Soriano GUILTY of Conduct Prejudicial to the Best Interest of the Service and SUSPENDS her for a period of six (6) months and one (1) day without pay, with a WARNING that a repetition of the same or similar act would warrant a more severe penalty.
Ratio Decidendi
On the issue of Soriano's administrative liability: The Court agrees with the OCA's factual findings that Soriano received P16,000.00 from Valdez with the promise to deliver it to the bank for his judgment obligation. However, the Court modifies Soriano's administrative liability. The Court clarifies that misconduct must relate to or be connected with the performance of official functions and duties. If the misconduct is not connected with the performance of duty, the proper designation is Conduct Prejudicial to the Best Interest of the Service. The Court finds that Soriano's acts of receiving the money and making Valdez believe she would deliver it, but failing to do so for over a year despite the proximity of the bank, tarnished the image and integrity of her public office. Valdez entrusted the payment to her because she was a court employee who assured him of delivery. Her failure to fulfill this promise and timely deliver the money reflected badly on her integrity and diminished public faith in the Judiciary, thus prejudicing the best interest of the administration of justice. Therefore, Soriano is liable for Conduct Prejudicial to the Best Interest of the Service, not Simple Misconduct. On whether Soriano's actions were within the scope of her official duties: The Court holds that Soriano's acts of receiving the money and making Valdez believe she would deliver the payment were not within her duties as a court stenographer. There is nothing that authorizes a stenographer to collect or receive any amount from any party-litigant, even during or after the termination of a case. Accepting money from a litigant for payment of a judgment obligation is not part of her official functions. Consequently, her misconduct was not in connection with the performance of her official duties, reinforcing the classification of her offense as Conduct Prejudicial to the Best Interest of the Service. The Court notes that her failure to deliver the money resulted in the judgment obligation incurring interests and penalties, for which she offered no justifiable explanation. Considering this is her first administrative case, the penalty of suspension for six months and one day is deemed proper under Section 50 (B) (10) of the 2017 Rules on Administrative Cases in the Civil Service.
Main Doctrine
A court stenographer who receives payment for a judgment obligation with the promise to deliver it to the bank, but fails to do so for over a year, is guilty of Conduct Prejudicial to the Best Interest of the Service, not Simple Misconduct, as the act is not within the scope of their official duties and tarnishes the image of the judiciary.