Case Digest (A.M. No. CTA-01-1) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Atty. Susan M. Aquino v. Hon. Ernesto D. Acosta (429 Phil. 498 [2002]), the complainant, Atty. Susan M. Aquino, Chief of the Legal and Technical Staff of the Court of Tax Appeals (CTA), filed an administrative complaint against Presiding Judge Ernesto D. Acosta on April 2, 2002, alleging six instances of sexual harassment under R.A. 7877, as well as violations of the Canons of Judicial Ethics and the Code of Professional Responsibility. The incidents occurred between November 21, 2000 and February 15, 2001, and involved unsolicited kisses on the cheek (“beso-beso”) and unwanted embraces, which Aquino claimed created an intimidating and offensive atmosphere. Judge Acosta denied any lascivious intent, explaining that his gestures were customary festive greetings and that on some dates he was on official leave. After Aquino submitted two joint affidavits of CTA staff corroborating his visits, and respondent presented affidavits and certifications refuting her allegations, the Su Case Digest (A.M. No. CTA-01-1) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Complaint Origin
- Atty. Susan M. Aquino, Chief of the Legal and Technical Staff of the Court of Tax Appeals (CTA), filed a sworn affidavit-complaint.
- Hon. Ernesto D. Acosta, Presiding Judge of the CTA, was charged with sexual harassment under R.A. 7877 and with violations of the Canons of Judicial Ethics and the Code of Professional Responsibility.
- Allegations by Complainant
- November 21, 2000 – Respondent entered complainant’s office, greeted her with a handshake, suddenly pulled her toward him and kissed her on the cheek.
- December 28, 2000 – Despite being on official leave, respondent called complainant, entered her office, shook her hand, embraced her and kissed her; corroborated by joint affidavit of two CTA specialists.
- Early January 2001 – Respondent summoned complainant to his chambers under the pretext of discussing official matters; attempted a kiss which complainant evaded.
- Post-Senate approval of CTA-expansion bill – In a public setting, respondent embraced and kissed complainant on the cheek amid celebratory “beso-beso” greetings.
- February 14, 2001 – Respondent called complainant to discuss the CTA health plan; no harassment occurred as meeting concerned official business.
- February 15, 2001 – Respondent again summoned complainant (accompanied by Ruby Lanuza); he forcefully held her arms and kissed her; complainant pushed him away and later locked herself in a comfort room.
- After last incident, respondent left a written apology note stating “sorry, it won’t happen again.”
- Respondent’s Denial and Defense
- Denied all allegations of sexual harassment; explained that the kisses were customary “beso-beso” gestures on festive occasions (Christmas, New Year, Valentine’s Day).
- Submitted affidavits and certifications (driver, HRMO, administrative staff) to show legitimate official reasons for his office visits and the absence of lascivious intent.
- Procedural History
- August 21, 2001 – Supreme Court referred the administrative complaint to Justice Josefina G. Salonga (Court of Appeals) for investigation, report, and recommendation.
- November 6–7, 2001 – Hearing conducted; parties rested; memoranda filed.
- January 9, 2002 – Justice Salonga submitted her Report, finding the complaint unsubstantiated, recommending dismissal and a warning to the respondent.
Issues:
- Whether Judge Acosta’s acts amounted to work-related sexual harassment under R.A. 7877.
- Whether those acts violated the Canons of Judicial Ethics or the Code of Professional Responsibility.
- What administrative sanction, if any, should be imposed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)