Case Digest (A.M. No. P-08-2472, RTJ-08-2106, P-08-2420)
Facts:
Judge Jenny Lind R. Aldecoa-Delorino v. Jessica B. Abellanosa, A.M. No. P-08-2472; Jessica B. Abellanosa v. Judge Jenny Lind R. Aldecoa-Delorino, A.M. No. RTJ-08-2106; and Jessica B. Abellanosa v. Rowena L. Ramos, A.M. No. P-08-2420, October 19, 2010, Supreme Court En Banc, Per Curiam, writing for the Court.These three administrative matters, filed against and by personnel of the Regional Trial Court (RTC), Makati City, Branch 137, were consolidated for investigation and resolution. The complaints at bar were: (1) an administrative complaint filed April 11, 2007 by Judge Jenny Lind R. Aldecoa-Delorino (Delorino) against Jessica B. Abellanosa, Court Stenographer III, for grave misconduct and violation of the Code of Conduct for Court Personnel and P.D. No. 1079; (2) a complaint dated June 22, 2007 filed by Abellanosa against Delorino for conduct prejudicial to the best interest of the service, abuse of authority and harassment; and (3) a complaint dated June 22, 2007 by Abellanosa against Rowena L. Ramos, Court Stenographer III, for inefficiency, extortion and dishonesty.
The factual allegations interwove. Delorino’s complaint accused Abellanosa of soliciting money from party-litigants in multiple matters: P8,000 from Mrs. Amapola Sapitula in People v. Bernard Sapitula; P20,000 from Atty. Gaudencio Palafox in Big Pix Graphics Systems, Inc. v. Josephine S. Velasco to facilitate an ex parte writ of preliminary attachment; P9,000 and later P6,000 from Beatrice Pena in People v. Winifredo F. Onio and Beatrice Pena for renewal of a bail bond; and sums (P9,500) from petitioners in two special proceedings to pay for publication of judicial orders allegedly without observance of the raffle requirement under P.D. No. 1079. Delorino also alleged disruptive work behavior and unauthorized removal of court property by Abellanosa.
Abellanosa denied the extortion charges and attributed money transfers variously to payments for transcripts or to Ramos acting in concert; she also counter-filed administrative charges accusing Delorino of hiring an outsider to draft decisions, coercing staff to resign or transfer, and favoring Ramos. Ramos denied the charges leveled against her and defended her performance and qualifications.
The Office of the Court Administrator (OCA) directed parties to comment. The Supreme Court consolidated the cases (Resolutions of January 23, 2008 and June 18, 2008) and referred them to Associate Justice Ramon R. Garcia of the Court of Appeals for investigation, report and recommenda...(Subscriber-Only)
Issues:
- Is there substantial evidence to hold Judge Delorino administratively liable for abuse of authority, conduct prejudicial to the best interest of the service, and harassment?
- Is there substantial evidence to hold Rowena L. Ramos administratively liable for inefficiency, extortion, and dishonesty?
- Is there substantial evidence to hold Jessica B. Abellanosa guilty of gross misconduct (solicitation/extortion and improper facilitation of publication contrary to P.D. ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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