TL;DR

The Supreme Court ruled that a court stenographer violated the rules by overcharging for transcripts of stenographic notes. The decision emphasizes that court employees must adhere to the prescribed fees for transcription services and serve the public interest over personal gain. This means stenographers cannot demand excessive payments or treat transcriptions as a private transaction, reinforcing the principle that public office is a public trust. By setting this precedent, the Court aims to ensure fair access to court records and uphold the integrity of the judicial system, making it clear that overcharging for stenographic work can result in suspension.

Beyond the Call: When Fair Fees Meet Public Duty

This case revolves around a complaint filed against Sonia Bagadiong, a court stenographer, for allegedly overcharging a litigant, Beatriz E. De Guzman, for transcripts of stenographic notes. De Guzman claimed she was charged an excessive amount per page and that the fees demanded were much higher than what she expected. This raised the core legal question of whether Bagadiong violated the prescribed fees for transcription services and whether her actions undermined the public’s trust in the judiciary.

The facts of the case reveal that De Guzman requested a copy of the transcript of stenographic notes from a court hearing. She was surprised to find that Bagadiong charged her P21.00 per page. De Guzman inquired about the propriety of this amount, also alleging that she was paying P800.00 for transcripts at every hearing. In response, Bagadiong justified the higher fee by claiming the transcripts were single-spaced and needed to be typed at home due to the complainant’s urgency. She also argued that she typically charged P10.00 per double-spaced page with more time provided and that the transcription was additional to her other court duties.

Bagadiong further argued that De Guzman should have exhausted administrative remedies by first raising the issue with the presiding judge. She also contended that the fees were a private matter between her and the complainant and did not affect her official duties. However, the Office of the Court Administrator (OCA) found these arguments unpersuasive. The OCA initially recommended a fine, but later, after reviewing additional comments from Bagadiong, suggested a three-month suspension without pay.

The Supreme Court anchored its decision on Section 10, Rule 141 of the Rules of Court, as amended by Administrative Circular No. 31-90. This section clearly stipulates the fees for stenographers, which is P5.00 per page before an appeal is taken. The Court emphasized that any deviation from this prescribed fee constitutes an administrative violation. As the Court stated in Alivia vs. Nieto,

The administration of justice is a sacred task; by the very nature of their duties and responsibilities, all those involved in it must faithfully adhere to, hold inviolate, and invigorate the principle solemnly enshrined in the 1987 Constitution that a public office is a public trust…

The Court rejected Bagadiong’s argument that transcription was merely an additional task. Administrative Circular No. 24-90 mandates that stenographers transcribe notes within twenty days and submit a verified monthly certification of compliance. The Court also pointed out that stenographic notes are official documents and cannot be removed from court records without authorization. Bagadiong admitted to taking the notes home without proper authorization, further solidifying the case against her.

The Supreme Court also referenced Rodas vs. Aquilizan, underscoring a court stenographer’s duty to serve the public, sometimes at the sacrifice of personal interest. By overcharging, Bagadiong undermined the judiciary’s commitment to public service. The Court noted that despite her years of service, Bagadiong seemed unaware of the basic concept of public service, which includes charging only the prescribed fees. The Court concluded that Bagadiong had indeed overcharged De Guzman for the stenographic notes, warranting disciplinary action.

Ultimately, the Supreme Court found Bagadiong guilty of violating the rules regarding the transcription of stenographic notes. As a result, she was suspended from office without pay for two months. The Court issued a stern warning that any similar offense in the future would be dealt with more severely, reinforcing the importance of adhering to prescribed fees and serving the public interest.

FAQs

This case serves as a crucial reminder to all court employees that public office is a public trust. Adherence to rules and regulations, especially concerning fees for services, is paramount in maintaining the integrity and credibility of the judiciary. This decision sets a clear precedent for the consequences of failing to uphold these standards.

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: De Guzman vs. Bagadiong, A.M. No. P-96-1220, February 27, 1998