A.M. No. P-08-2472, RTJ-08-2106, P-08-2420 - Aldecoa-Delorino vs. AbellaNo.

Three administrative cases were consolidated because their antecedent facts were intertwined:

A.M. No. P-08-2472 – Judge Jenny Lind R. Aldecoa-Delorino (Delorino) filed an administrative complaint against Jessica B. Abellanosa for grave misconduct, violation of the Code of Conduct for Court Personnel, and breach of Presidential Decree No. 1079.
A.M. No. RTJ-08-2106 – Jessica B. Abellanosa filed a complaint against Judge Delorino for conduct prejudicial to the best interest of the service, abuse of authority, and harassment.
A.M. No. P-08-2420 – Jessica B. Abellanosa filed a complaint against Rowena L. Ramos for inefficiency, extortion, and dishonesty.

In People v. Bernard Sapitula (Criminal Case No. 02-2101), it was alleged that Abellanosa solicited P8,000.00 from Mrs. Amapola Sapitula for the purpose of influencing Prosecutor George V. De Hoya regarding the filing of motions.
In Big Pix Graphics Systems, Inc. v. Josephine S. Velasco (Civil Case No. 06-451), Abellanosa was accused of receiving P20,000.00 from Attorney Gaudencio A. Palafox to facilitate the ex parte issuance of a writ of preliminary attachment.
In People v. Winifredo F. Onio and Beatrice PeAa (Criminal Case No. 03-501-502), Abellanosa allegedly solicited P9,000.00 (and later P6,000.00) from the accused, promising to renew bail bonds.
In two special proceedings (Petitions for Correction of Entries in Certificates of Live Birth), Abellanosa was accused of instructing petitioners to remit P9,500.00 for the publication of judicial orders, with the publication not conforming to the mandated procedure by PD No. 1079.
Additionally, it was noted that Abellanosa exhibited alleged unruly and disruptive behavior while still in Branch 137 and that she removed certain court items from the premises, only returning them after demand.

She denied soliciting money for influencing court actions and maintained that any receipt of money was solely for the payment of stenographic transcripts or publication expenses.
She attributed the accusations in part to personal conflicts, including alleging that witnesses testified against her for reasons of personal gain or favoritism toward Judge Delorino.
She also claimed that for certain transactions (e.g., the P20,000.00 from Palafox), the funds were handled by Rowena Ramos.

Abellanosa accused Delorino of abusing her authority by allegedly employing Socrates Manarang to draft decisions and resolutions, which involved taking court case records outside the premises.
It was asserted that Delorino coerced several employees (including the Branch Sheriff and other personnel) to either transfer to another office or resign, with specific reference to the treatment of Arnel Padlan.
Abellanosa claimed that Delorino used her position to influence testimonies against her (particularly from witnesses such as PeAa and Sapitula).
An additional allegation was that Delorino showed favoritism toward Rowena Ramos by protecting her in spite of evidence of anomalous transactions.

Delorino contended that Abellanosa’s complaint was retaliatory in nature and fabricated.
She clarified that any administrative action, including the detailed transfer or voluntary resignation of employees (like Padlan), was backed by proper procedures.
Delorino produced evidence and affidavits (including those from Socrates Manarang and the branch personnel) to demonstrate that the assignment of cases and employee transfers complied with judicial administrative protocols.
She refuted the claim of favoritism by explaining that the decisions regarding appointment and assignment were either precedented or outside her control.

Abellanosa alleged that Ramos was inefficient in performing stenographic duties and was involved in demanding money from litigants, especially under the guise of facilitating the renewal of bail bonds.
It was claimed that Ramos also arranged for another person to take the Civil Service Examination on her behalf.
Furthermore, there was an accusation that Ramos used her influence to secure continuous assignment for her husband, Lyndon Ramos, at Branch 137.

Ramos firmly denied the charges, asserting that her performance as a stenographer was rated “very satisfactory” by her superiors.
She argued that the allegations regarding solicitation of money and misuse of influence were unfounded and solely an attempt by Abellanosa to deflect from her own misconduct.
Ramos also refuted the claim regarding unauthorized assistance with civil service examinations.

The cases were re-raffled to Justice Ramon R. Garcia for investigation, report, and recommendation.
The Investigating Justice recommended dismissal of the complaints against both Delorino and Ramos for insufficiency of evidence, while finding Abellanosa guilty of gross misconduct.

Whether substantial and convincing evidence exists to hold Jessica B. Abellanosa liable for soliciting money from party-litigants and for facilitating judicial transactions in violation of procedural requirements, particularly PD No. 1079.
Whether evidence sufficiently supports the allegations that Judge Delorino abused her authority, engaged in harassment, and coerced the transfer or resignation of court employees.
Whether the charges against Rowena Ramos for inefficiency, extortion, and manipulation of administrative assignments are substantiated by clear and convincing evidence.

Whether the evidence presented by the complainants (including affidavits, transcripts of stenographic notes, and official records) meets the standard of “substantial evidence” necessary in administrative proceedings.
Whether the denials and defenses by the respondents are credible in light of the testimonies and documentary evidence provided.

Whether Abellanosa’s conduct, as evidenced by soliciting funds and facilitating improper publication of judicial orders, constitutes gross misconduct warranting dismissal from service.
Whether the actions or inactions of Judge Delorino and Rowena Ramos fall within the ambit of administrative liability or whether they are exonerated by the lack of corroborative evidence.