Upholding Decorum: Judicial Employees' Duty to Maintain Respect and Civility in the Workplace

The Supreme Court has long emphasized that those working in the judiciary must be living examples of uprightness and decorum. In Bajar v. Baterisna (A.M. No. P-06-2151, August 26, 2006), the Court dealt with a records officer who berated a colleague in front of other employees and even before the Clerk of Court. The case serves as a clear reminder that judicial employees must maintain respect and civility not only in performing their duties but also in their dealings with co-workers.

The Facts of the Case

Maria Raquel R. Bajar, a Records Officer III, filed an administrative complaint against Victoriano P. Baterisna, a Records Officer II, both assigned to the Office of the Clerk of Court of the Regional Trial Court of Manila. The complaint charged Baterisna with insubordination, disrespect, and conduct unbecoming a court employee.

The incident began when Bajar and another employee went to the Bodega room to verify a complaint that it was locked from the inside during office hours. After knocking repeatedly, the door was opened and they found Baterisna inside with other employees. Bajar issued a memorandum reminding him that the room was for official use and should be open during office hours.

Baterisna refused to receive the memorandum. Later that same afternoon, he went to Bajar's office and berated her in the presence of her staff, questioning her authority and making personal attacks. The following day, when both parties were summoned to the Clerk of Court's office to settle the matter, Baterisna again made disrespectful and abusive remarks against Bajar in the presence of their superior.

The Issue

The central question was whether Baterisna's conduct constituted gross discourtesy in the performance of official duties, warranting administrative sanction.

The Court's Ruling

The Supreme Court found Baterisna administratively liable. The Court noted that Baterisna had not successfully disputed the charges. More importantly, he admitted his brash behavior in written apologies to both Bajar and the Clerk of Court, acknowledging that he "was not able to control his temper" during the incidents.

The Court stressed that the conduct and behavior of everyone connected with an office charged with the dispensation of justice are circumscribed with a heavy burden of responsibility. The Constitution mandates that all public officers and employees should serve with responsibility, integrity, loyalty, and efficiency, as a public office is a public trust.

Fighting between court employees during office hours is a disgraceful behavior that reflects adversely on the good image of the judiciary. Shouting at one another in the workplace displays arrant discourtesy and disrespect not only towards co-workers but also to the court itself.

The Court emphasized that high-strung and belligerent behavior has no place in government service. Personnel are enjoined to act with self-restraint and civility at all times, even when confronted with rudeness and insolence. This standard applies to court employees' dealings not only with the public but also with their co-workers.

The Court also addressed Baterisna's argument that the administrative case should have been dismissed because Bajar desisted from the criminal complaint she had filed. The Court ruled that the withdrawal or desistance of a complainant does not divest the Court of its disciplinary authority over court personnel.

The Penalty

Under the Civil Service Rules, gross discourtesy in the performance of official duties is a less grave offense punishable with suspension from one month and one day to six months. The Court suspended Baterisna for one month and one day, with a stern warning that the commission of the same or similar acts in the future would be dealt with more severely.

Practical Takeaways

• Civility is a professional requirement. Judicial employees must act with self-restraint and courtesy at all times, even when provoked or confronted with rudeness.
• The standard applies to co-worker relations. Respect and decorum are required not only in dealing with the public but also in interactions among colleagues in the workplace.
• Admissions are binding. An employee who admits to rude behavior in written apologies cannot later deny the allegations in an administrative case.
• Desistance does not end administrative cases. The withdrawal of a criminal complaint does not prevent the Court from exercising its disciplinary authority over court personnel.
• Gross discourtesy carries real penalties. Suspension of one month and one day to six months may be imposed for this offense under the Uniform Rules on Administrative Cases in the Civil Service.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.