SC: Court cannot discipline LGU employee detailed without approval



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The Supreme Court has ruled that it cannot impose administrative sanctions on a local government employee detailed to a lower court without its approval, although the employee may still be cited for contempt.
In a decision dated 29 January 2026 and written by Associate Justice Maria Filomena D. Singh, the Court’s Third Division directed the executive judge of the Municipal Trial Court in Cities in Baguio City to initiate contempt proceedings against former Baguio City government employee Juliet L. Corpuz.
Corpuz had been detailed to the MTCC without prior approval from the Supreme Court through the Office of the Court Administrator.
The case stemmed from a complaint filed by a man identified as “Mr. Abenes,” who discovered that his marriage solemnized at the MTCC had not been registered with the local civil registrar.
Abenes alleged that Corpuz failed to register the marriage despite receiving a P500 registration fee.
When he asked her to process the registration, Corpuz reportedly said she could not do so because she had been suspended from office at the time.
She instead allegedly asked him to pay P5,000 so she could prepare another marriage certificate even without a marriage license.
When Abenes threatened to file a complaint, Corpuz argued that the Court had no jurisdiction over her because she was an employee of the Baguio City government who had only been detailed to the MTCC.
The complaint was filed before the OCA, which referred the matter to the Regional Trial Court executive judge for investigation.
The investigating judge found that Corpuz had received money from several couples whose marriages had been solemnized by the MTCC but had not been registered with the local civil registry.
The OCA Legal Office also found that Corpuz’s detail to the MTCC had not been approved by the Court as required under Administrative Circular No. 28-2008.
The Judicial Integrity Board recommended that Corpuz be held administratively liable and fined P150,000.
While the Supreme Court agreed with the OCA and JIB that Corpuz committed acts that undermined the image of the courts, it declined to impose an administrative penalty.
The Court explained that local government units may assign locally funded employees to first- or second-level courts to help in the administration of justice.
Under Administrative Circular No. 28-2008, however, such assignments require prior approval from the Supreme Court through the OCA.
Without that approval, the detail is void and the Court does not acquire administrative supervision or disciplinary jurisdiction over the employee.
The Supreme Court stressed, however, that this does not place locally funded employees beyond its authority.
It said courts retain the inherent power to cite a person in contempt for conduct that impedes, obstructs or degrades the administration of justice.
Although Corpuz was employed by the Baguio City government, the Court said she performed duties at the MTCC and appeared to the public as a court employee.
Her alleged acts therefore tarnished the reputation of both the MTCC and the judiciary as a whole, the Court said.
The Supreme Court also noted that locally funded employees remain under the administrative supervision of their respective LGUs.
Since Corpuz was no longer connected with the Baguio City government, the Court said referring the administrative case to the LGU would serve no practical purpose.
It instead directed the MTCC executive judge to initiate contempt proceedings and determine whether Corpuz should also be barred from future employment in the judiciary.