Court Personnel Must Answer Written Inquiries Promptly: A Lesson from A.M. No. P-04-1912

The Supreme Court has long held that those who work in the judiciary must observe the highest standards of professionalism and accountability. A 2004 decision involving a clerk of court and a clerk III of the Metropolitan Trial Court of Quezon City serves as a clear reminder: court personnel who receive written inquiries from the public must reply in writing and within the period fixed by law. A mere verbal response, no matter how well-intentioned, will not suffice.

The Facts

In January 1997, the National Housing Authority (NHA) filed an ejectment case against Eduardo S. Yap before Branch 31 of the Metropolitan Trial Court of Quezon City. The case was docketed as Civil Case No. 16995. On May 16, 2001, the trial court ruled in favor of the NHA. Yap appealed, but the NHA claimed it never received the letter transmitting the records to the appellate court, as required by Rule 40, Section 6 of the Rules of Court.

On February 18, 2003, the NHA's Legal Department wrote to the clerks of court of both the Regional Trial Court and the Metropolitan Trial Court, Branch 31, asking about the status of the records. The NHA received no response. Several follow-ups were made, but the court personnel allegedly gave various reasons: the records were under inventory, the folder was still being located, or the folder was among those bundled at the lower ground of the court building. At one point, the NHA was told that if it was in a hurry, it should send its own staff to help locate the records.

The NHA then filed an administrative complaint against Branch Clerk of Court Edilaida D. Ente-Alcantara and Clerk III Amelia S. Loja for misfeasance and conduct prejudicial to the best interest of the service.

The Issue

The central question was whether the two respondents should be held administratively liable for the delay in transmitting the records and for failing to properly respond to the NHA's written inquiry.

The Ruling

The Supreme Court dismissed the complaint against Ente-Alcantara. She assumed her post only on August 8, 2003, long after the alleged delay occurred. She could not be faulted for an omission that happened before her time.

The case against Loja was different. She admitted that the NHA had sent a written letter of inquiry but said she merely told the NHA's messenger that she was doing her best to locate the records. The Court found this insufficient.

Under Section 5(a) of R.A. No. 6713, the Code of Conduct and Ethical Standards for Public Officials and Employees, all public officials and employees must respond to letters, telegrams, or other means of communication sent by the public within fifteen (15) working days from receipt. The reply must state the action taken on the request. The Chief Justice reiterated this duty in Administrative Circular No. 8-99, issued on July 2, 1999, which reminded all judiciary personnel to strictly observe this requirement.

The Court held that a verbal reply to a formal written inquiry is not enough. Loja, as an officer of the court, was expected to show a high degree of professionalism. Since this was her first offense, the Court imposed the penalty of reprimand, with a warning that a repetition would be dealt with more severely. The Court noted that the violation is classified as a light offense under the Uniform Rules on Administrative Cases in the Civil Service, which carries a reprimand for a first offense.

Why This Matters

The decision underscores a simple but critical rule: public offices, especially courts, must treat written inquiries with the seriousness they deserve. A written question deserves a written answer, given on time. The duty to respond promptly is not a mere formality; it is a legal obligation that upholds public trust in the judiciary.

Practical Takeaways

• Written inquiries require written replies. A verbal response, even if sincere, does not comply with Section 5(a) of R.A. No. 6713.
• The 15-working-day rule is strict. Public officials and employees must respond within 15 working days from receipt of any letter, telegram, or similar communication.
• Court personnel are held to a higher standard. From judges to the most junior clerk, everyone in the judiciary must act with professionalism and accountability.
• Ignorance of a prior employee's lapse is a defense. A newly appointed employee cannot be held liable for delays that occurred before their assumption of duty.
• First offenses may merit leniency. A light offense under the civil service rules may result in a reprimand, but repeated violations will be punished more severely.

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