HON. MONTANO C. MEDEL, JR., COMPLAINANT, VS. AILEEN L. GUILLEN, FORMER UTILITY WORKER I, BRANCH 2, MUNICIPAL TRIAL COURT IN CITIES, BACOLOD CITY, NEGROS OCCIDENTAL, RESPONDENT.

Medel versus Guillen

The Case

This is an administrative disciplinary case. Judge Montano Medel, Jr., the presiding judge of a municipal trial court in Bacolod City, filed an incident report against Aileen Guillen, a utility worker in his own sala, for charging irregular fees to couples whose marriages were solemnized before him. The case matters for two reasons. First, it settles that resignation does not extinguish administrative liability. Second, and more important for the Bar, it fixes the correct designation of the offense when a court employee's misconduct has no direct relation to official duties: not gross misconduct, but prejudicial conduct that gravely besmirches or taints the reputation of the service under Rule 140 of the Rules of Court, as amended.

Procedural History

The case began with an incident report dated September 12, 2019, submitted by Judge Medel to the Office of the Court Administrator. The Office of the Court Administrator sent three indorsements directing Guillen to comment on the charges. Registry return receipts showed she received them, but she never complied. The matter was referred to the Judicial Integrity Board, which, in a report and recommendation dated July 1, 2024, found her liable for gross misconduct and recommended dismissal, but since she had already resigned, recommended forfeiture of benefits except accrued leave credits, and perpetual disqualification from reemployment in government. The case then went to the Supreme Court as an administrative matter, decided en banc.

Facts

In April 2019, a couple, Shaneen Vasquez Bacong and her husband, were preparing for a wedding to be solemnized by Judge Medel. Guillen sent Shaneen a text message demanding 100 pesos from each of their 21 wedding sponsors, or a total of 2,100 pesos. On April 24, 2019, during the ceremony, Guillen handed Shaneen's mother an envelope, saying it was for cash collection from the principal sponsors. Six days later, the couple went to the court to pay. The branch clerk of court told them the court collects nothing from sponsors. Guillen, standing beside the clerk, denied making any demand, so Shaneen showed Guillen's own message to the clerk and to Judge Medel.

Judge Medel had already issued memoranda to Guillen. One reminded the staff to lock the courtroom and to stop Guillen from transacting and processing marriages because of her exorbitant fees. Another directed her to explain, within 72 hours, why she should not be liable for charging 100 to 200 pesos per sponsor and an additional 2,000 pesos, termed "to expedite," for the release of a marriage contract from the Philippine Statistics Authority. A further memorandum called out her practice of borrowing money from litigants. Judge Medel attached demand letters from several creditors, including a lending company, for debts ranging from 20,000 pesos to over 342,000 pesos.

On August 28, 2019, Guillen tendered her resignation. She never filed a comment despite the three directives of the Office of the Court Administrator.

Issues

• Whether or not Guillen's resignation pending investigation extinguished her administrative liability.
• Whether or not her failure to file a comment despite three directives constituted a waiver of her right to defend herself and an implied admission of the allegations.
• Whether or not her acts constituted gross misconduct, or the offense of prejudicial conduct that gravely besmirches or taints the reputation of the service.
• Whether or not the penalty of dismissal may be imposed, and if not, what penalty applies in lieu of dismissal.

Applicable Provisions

Section 14, paragraph l, of Rule 140 of the Rules of Court, as amended, defines the offense the Court ultimately applied:

Prejudicial conduct that gravely besmirches or taints the reputation of the service.

The Court's annotations under the same Rule explain its scope, and the Court quoted them:

This charge is added to cover acts or omissions which are not strictly part of the performance of one's official functions, but nonetheless are punished as they diminish or tend to diminish the people's faith in the Judiciary.

Section 17 of the same Rule supplies the penalties in lieu of dismissal for a respondent already separated from the service:

Forfeiture of all or part of the benefits as the Supreme Court may determine, and disqualification from reinstatement or appointment to any public office, including government-owned or -controlled corporations. Provided, however, that the forfeiture of benefits shall in no case include accrued leave credits; and/or a fine of more than 100,000 pesos but not exceeding 200,000 pesos.

These provisions bear on the case because they fix both the name of the offense and the penalty that may replace dismissal.

Ruling

On the first issue, the Court held that Guillen's administrative liability subsists notwithstanding her resignation. Resignation is not a way out to evade administrative liability when court personnel face an administrative sanction. Her resignation, coming after the memoranda and the demand letters, was obviously done to avert the formal filing of charges.

On the second issue, the Court held that her repeated failure to comment, despite three directives, waived her right to defend herself. Her silence operated as a tacit admission of the allegations. The Court quoted its ruling in Mendoza versus Tablizo:

It is totally against human nature to remain silent and say nothing in the face of false accusations.

On the third issue, the Court modified the finding of the Judicial Integrity Board. It held that misconduct, whether simple or gross, must have a direct relation to and be connected with the performance of the court personnel's official duties. Where the act is not so connected, the proper designation is prejudicial conduct that gravely besmirches or taints the reputation of the service. To fall under this offense, the act must be without a direct relation to official duties, and must not be covered by any other specific offense in the Rules. Any prior rulings designating such acts as gross misconduct are deemed abandoned. The Court found Guillen had acted as a fixer, exploiting her position and misleading the public, and that it mattered not that her acts were not work-related.

On the fourth issue, since the offense is a serious one but Guillen had already resigned, the Court imposed, in lieu of dismissal, a fine of 150,000 pesos, forfeiture of benefits except accrued leave credits, and perpetual disqualification from reinstatement or appointment to any public office.

Doctrine

First, resignation pending investigation does not render an administrative case moot; it does not extinguish liability. Second, failure to answer administrative charges despite notice constitutes a waiver of the right to defend and an implied admission of the allegations. Third, and the rule to memorize: misconduct, simple or gross, requires a direct relation to official duties. If the act has no such connection and is not covered by another specific offense, it is prejudicial conduct that gravely besmirches or taints the reputation of the service under Section 14, paragraph l, of Rule 140. Fourth, for a respondent already separated from the service, the penalty in lieu of dismissal is forfeiture of benefits except accrued leave credits, disqualification from public office, and a fine of more than 100,000 pesos but not exceeding 200,000 pesos.

Disposition

Guillen was found guilty of prejudicial conduct that gravely besmirches or taints the reputation of the service, and in lieu of dismissal, was fined 150,000 pesos, with all benefits forfeited except accrued leave credits, and perpetually disqualified from reemployment in any branch or instrumentality of the government.

Remember This

Memorize the line: misconduct must have a direct relation to official duties; if it does not, the offense is prejudicial conduct that gravely besmirches or taints the reputation of the service. Examiners use this case to test the correct designation of the offense under Rule 140 and the rule that resignation is no escape from administrative liability.