Juntilla v. Calleja

A.M. No. P-96-1225 OCA I.P.I. No. 95-56-P (September 23, 1996)

Facts:

Anatolia A. Juntilla filed an administrative complaint against Atty. Teresita J. Calleja, the Branch Clerk of Court, and Salome A. Montezon, a Court Stenographer, both of the Regional Trial Court (RTC), Branch 7, Tacloban City. The complaint arose from alleged acts that were grossly prejudicial to her in Special Proceedings Case No. 1353, concerning the intestate estate of her deceased sister, Serafin A. Juntilla.

The background of the case is as follows: On November 16, 1984, Juntilla filed a verified petition with the RTC seeking letters of administration over her sister's estate, claiming that her sister's common-law husband and foster daughter were dissipating the properties. The RTC granted her the letters of administration on January 31, 1985, contingent upon posting a bond and submitting an inventory of the deceased's properties. The common-law husband, Pablo de los Santos, opposed the petition, asserting that he was legally married to the deceased and that the properties were conjugal assets. The trial court ultimately dismissed Juntilla's case due to her failure to file a formal offer of evidence.

Juntilla appealed the dismissal, but she alleged that the respondents conspired to withhold stenographic notes that would have supported her case in the Court of Appeals. She claimed that from 1990 until the judgment was rendered, no stenographic notes were submitted in her favor, which adversely affected her chances of winning the appeal. She discovered the absence of these notes only when she personally requested a copy of the case records in preparation for her appeal to the Supreme Court.

In their comments, both respondents denied any wrongdoing. Atty. Calleja argued that as a Branch Clerk of Court, she had no control over the stenographers and could only advise them to submit their transcripts. Montezon contended that she had submitted her stenographic notes along with the case records to the Court of Appeals and that there was no follow-up from the appellate court regarding the transcript.

Legal Issues:

1. Whether Atty. Teresita J. Calleja, as Branch Clerk of Court, failed in her duty to ensure the timely submission of the stenographic notes.
2. Whether Salome A. Montezon, as Court Stenographer, neglected her duty to transcribe and submit the stenographic notes within the required timeframe.

Arguments:

• Complainant's Arguments:

  • Juntilla argued that the failure to submit the stenographic notes prejudiced her case and led to the dismissal of her appeal.
  • She claimed that the respondents conspired to withhold the notes, which were crucial for her to present her evidence effectively.

• Respondents' Arguments:

  • Atty. Calleja maintained that she had no direct control over the stenographers and had taken steps to request the submission of the transcripts.
  • Montezon asserted that she had submitted her notes and that the responsibility for the transmission of the case records lay with the Clerk of Court.

Court's Decision and Legal Reasoning:

The court agreed with the findings of the Office of the Court Administrator (OCA) but disagreed with its recommendations. The court found that Montezon had failed to comply with her duty to transcribe and submit the stenographic notes within the required period, which was a clear dereliction of duty. The court emphasized that the responsibility of timely transcription and submission of notes lies with the stenographer, and her failure to do so jeopardized the integrity of the judicial process.

Regarding Atty. Calleja, the court held that as the Branch Clerk of Court, she had a duty to ensure that the stenographer complied with her obligations. The court found that Calleja was remiss in her duties when she misrepresented to the Court of Appeals that the records had been forwarded, despite knowing that the stenographic notes had not been transcribed.

The court imposed fines on both respondents: Atty. Calleja was fined P1,000.00 and admonished to supervise court personnel strictly, while Montezon was fined P3,000.00 for her dereliction of duty and warned that any future violations would be dealt with more severely.

Significant Legal Principles or Doctrines Established:

1. The duty of court stenographers to transcribe and submit their notes within a specified timeframe is critical to the administration of justice.
2. The Clerk of Court has a supervisory role over court personnel and must ensure compliance with procedural requirements to maintain the integrity of the judicial process.
3. Public officers, including those in the judiciary, are held to high standards of accountability and must perform their duties diligently to uphold public trust in the judicial system.