LEONILA R. PEDRO, COMPLAINANT, VS. LORNA M. CLEMENTE, COURT STENOGRAPHER I, MUNICIPAL CIRCUIT TRIAL COURT, ROXAS-QUIRINO, ISABELA, RESPONDENT.

Pedro versus Clemente

The Case

This is an administrative complaint filed by Leonila Pedro against Lorna Clemente, a Court Stenographer in the Municipal Circuit Trial Court of Roxas-Quirino, Isabela. Pedro accuses Clemente of gross misconduct violating the Code of Conduct for Court Personnel, direct bribery and violation of the Anti-Graft and Corrupt Practices Act, and grave abuse of authority or prejudicial conduct that taints the reputation of the service. The case matters because it shows how the Supreme Court treats court personnel who exploit the trust of litigants, and it illustrates the application of the new 2025 Code of Conduct and Accountability for Court Officials and Personnel to a pending administrative case.

Procedural History

The complaint began as a sworn statement and reklamo dated August 19, 2022, which the Court Administrator referred to the Judicial Integrity Board by indorsement dated September 22, 2022. The Judicial Integrity Board required Clemente to comment on the charges. After the parties filed their pleadings, the Judicial Integrity Office rendered a Report and Recommendation dated October 28, 2025, finding Clemente guilty of gross misconduct constituting violations of the Code of Conduct for Court Personnel and recommending forfeiture of benefits and perpetual disqualification. The case then came before the Supreme Court as an administrative matter, and the Court resolved it in this decision.

Facts

Pedro first met Clemente through a friend who introduced them, because Pedro was looking for help in recovering 520,000 pesos owed to her by Marlene Sagun. Pedro trusted Clemente because she was a court staff member. According to Pedro, Clemente told her she had to pay docket fees and other processing fees totaling 20,000 pesos, which Pedro paid. Later, Clemente allegedly informed Pedro that Sagun was willing to settle, and Pedro collected the 520,000 pesos at the court branch. Pedro claims Clemente then asked for 30,000 pesos as a processing fee, which Pedro paid, bringing her total payments to Clemente to 50,000 pesos for the Sagun matter.

Pedro then sought Clemente's help with another concern: two allegedly unfunded checks issued by Corazon Pineda amounting to 1.2 million pesos and 200,000 pesos. Pedro claims Clemente told her a warrant of arrest might be issued against Pineda for violation of Batas Pambansa Blg. 22, and later demanded a package fee of 200,000 pesos, with a breakdown totaling 197,200 pesos. Pedro borrowed money and paid 89,200 pesos as partial payment, then delivered a final payment of 110,000 pesos. In return, Clemente allegedly gave her two receipts under the name of Attorney David Salibad, Jr., amounting to 110,000 pesos and 30,000 pesos, explaining that the lawyer would represent her.

Pedro later learned that the small claims case had been dismissed, and that she should have paid only 26,700 pesos in fees. After many attempts, Clemente returned 24,000 pesos in installments from May 2021 to September 2021. When Pedro sought help from the municipal mayor's office, Clemente provided official receipts under Attorney Salibad's name, but the lawyer said he received only much lower amounts. Clemente denied the allegations, claiming she only helped Pedro out of kindness and that she never received the amounts claimed. The Judicial Integrity Office found insufficient evidence on the Sagun case but found the Pineda allegations more plausible, concluding that Clemente interfered in Pedro's cases and accepted remuneration beyond what she was entitled to.

Issues

• Whether or not Clemente is administratively liable for gross misconduct constituting violations of the Code of Conduct for Court Personnel.
• Whether or not the 2025 Code of Conduct and Accountability for Court Officials and Personnel applies to this pending case.
• Whether or not the quantum of proof of substantial evidence supports a finding of guilt against Clemente.

Applicable Provisions

Canon II, Section 4 of the 2025 Code of Conduct and Accountability for Court Officials and Personnel provides:

SECTION 4. Prohibition against improper communications. - Except on official matters when allowed by the rules, court officials and personnel shall not communicate with lawyers, litigants, or their representatives, including on any social networking platform, on any pending matter before their office.

This provision bears on the case because Clemente repeatedly communicated with Pedro, a litigant, about matters pending before her office.

Canon II, Section 12, paragraph f of the same Code provides:

(f) Directly or indirectly solicit or accept from court users, lawyers, litigants, or third parties dealing with the Judiciary, any gift, bequest, or favor, of any value on any occasion, except unsolicited gifts of small or insignificant value as a mere token of gratitude or friendship according to local customs and usage[.]

This provision bears on the case because Clemente accepted monetary consideration for her assistance to Pedro.

Canon III, Section 4 of the same Code provides:

SECTION 4. Prohibition on recommending lawyers. - Court officials and personnel shall not recommend lawyers to litigants, prospective litigants, or anyone dealing with the Judiciary for personal interest or pecuniary gain.

This provision bears on the case because Clemente linked Pedro to Attorney Salibad and facilitated their transactions.

Canon III, Section 8 of the same Code provides:

SECTION 8. Nonacceptance of gifts and tips. - Court officials and personnel shall not receive gifts, tips, or other gratuities for assisting or attending to litigants, lawyers, or other court users.

This provision bears on the case because Clemente received payments for assisting Pedro with her cases.

Ruling

On the first issue, the Court held that Clemente is administratively liable. The Court adopted the findings of the Judicial Integrity Office that Pedro failed to substantiate her allegations regarding the Sagun case, but found that the evidence clearly proved Clemente advocated on behalf of Pedro's case, intervened in Pedro's professional transactions with her counsel, and received monetary consideration for her assistance. The Court gave little credence to Clemente's justification that she was moved only by kindness, noting her constant communications with Pedro, her assistance with the lawyer, and her payment of 24,000 pesos in installments. The Court stressed that court employees must act with a high degree of professionalism and responsibility, and that their conduct must not only be characterized by propriety and decorum but must also be in accordance with the law and court regulations.

On the second issue, the Court applied the 2025 Code of Conduct and Accountability for Court Officials and Personnel. The Court noted that under the Code's transitory clause, it shall be applied to all pending and future cases, except to the extent that its retroactive application would not be feasible or would work injustice. Finding no reason to the contrary, the Court decided the case by applying the new Code.

On the third issue, the Court held that the quantum of proof in administrative proceedings is substantial evidence, or that amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion. The Court found that this standard was met as to the Pineda cases. The Court also noted that Pedro was not faultless, but that whatever her own faults may be, the acts of Clemente must be judged in their own light.

Doctrine

Court officials and personnel are held to a higher standard of professional and ethical conduct. They must embody independence, propriety, impartiality and equality, competence and diligence, and accountability. Any act or omission that departs from these standards imperils public trust in the Judiciary and undermines the rule of law. Court employees, from the presiding judge to the lowliest clerk, should always act with a high degree of professionalism and responsibility, and their conduct must not only be characterized by propriety and decorum but must also be in accordance with the law and court regulations.

In administrative proceedings, the quantum of proof necessary for a finding of guilt is substantial evidence, or that amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion. The burden of substantiating the charges falls on the complainant. The Court is not bound by technical rules of procedure and evidence in assessing whether substantial evidence exists.

The 2025 Code of Conduct and Accountability for Court Officials and Personnel applies to all pending and future cases, except to the extent that its retroactive application would not be feasible or would work injustice. Court officials and personnel must not communicate with litigants on pending matters before their office, must not solicit or accept gifts or favors from court users, must not recommend lawyers for personal interest or pecuniary gain, and must not receive gifts, tips, or other gratuities for assisting litigants.

Disposition

The Court found Clemente guilty of gross misconduct constituting violations of the Code of Conduct for Court Personnel, and given her optional retirement, imposed the forfeiture of all or part of her benefits, except accrued leave credits, and perpetual disqualification from reinstatement or appointment to any public office.

Remember This

The single line worth memorizing is that court employees must not only be free from impropriety but must also be perceived to be so, and any act that departs from this standard imperils public trust in the Judiciary. Examiners like to use this case to test the quantum of proof in administrative proceedings and the application of the 2025 Code of Conduct and Accountability for Court Officials and Personnel to pending cases.