Facts:

The case involves Iluminada P. Atienza as the complainant and Angelita L. Perez as the respondent. The events leading to the complaint occurred on October 12, 1973, in the office of the City Court of Manila, where both women were employed. Atienza, a cash clerk, filed a verified complaint against Perez, the personnel officer, on December 10, 1973, alleging multiple counts of misconduct. The complaint consisted of seven counts, but the Court, in its resolution dated July 9, 1974, found Perez's explanations satisfactory for six of the counts, leading to their dismissal. However, the Court ordered that the charge of grave misconduct and discourtesy during official duty be referred to the executive judge of the city court for further investigation. This investigation was conducted by Judge Alejandro Galang, Jr. in August 1974, as the executive judge, Antonio M. Consing, inhibited himself due to a petition from Atienza. During the investigation, both parties and their witnesse...

Facts:

Background of the Case

• The case involves a disciplinary matter arising from an altercation between Iluminada P. Atienza (complainant and cash clerk in the City Court of Manila) and Angelita L. Perez (respondent and personnel officer of the same court).
• The incident took place on October 12, 1973, in the office premises of the respondent, which were converted into an arena for a public altercation.

Nature of the Incident

• The disagreement arose following an anonymous letter received by the respondent, which she suspected was authored by the complainant’s sister.
• Both parties appeared to have approached the situation with belligerence:
• Complainant deliberately went to the respondent’s office to "disabuse" her of a mistaken notion.
• Respondent, in turn, reacted in a manner that escalated the situation, including physical actions such as dropping a folder and throwing liquid.
• Evidence indicates that, beyond the physical actions, the conduct of both parties displayed a lack of self-control, thereby compromising the decorum expected in government service.

Accounts and Evidence Presented

• Testimony of Mr. Florencio Cabrera (special deputy clerk):
• He recounted that the complainant was the one who approached the respondent’s desk, leading to an exchange of words.
• Witnessed the altercation: the complainant grabbed and threw a folder at the respondent, and respondent retaliated by throwing a liquid (coke or coffee).
• His calm and dispassionate testimony was contrasted with witness testimony from other complainant-provided individuals, who failed to clarify the sequence of events.
• Respondent’s Account in Her Answer:
• Respondent admitted to engaging in disruptive conduct, including grabbing folders, scattering official documents, and hurling heavy objects (a high‐heeled shoe) in a bid to remove the complainant from her table.
• Her narrative, while corroborating elements of the confrontation, also emphasized the physical nature and intensity of the response.
• Findings from the Investigation:
• The investigation, conducted by City Court Judge Alejandro Galang, Jr. in August–September 1974, involved the hearing of both parties and their witnesses with legal assistance.
• The investigation report concluded that the complainant had incited the altercation by her deliberate actions, though it also established that both parties behaved in an indecorous and belligerent manner.

Disciplinary Proceedings and Orders

• Prior Resolution from July 9, 1974:
• The Court resolved six of the seven counts in the complainant’s verified complaint in favor of the respondent by dismissing the charges due to her satisfactory explanation on those counts.
• However, the charge for grave misconduct and discourtesy was referred to the city court’s executive judge for further investigation.
• Final Disciplinary Order:
• The Court administered a penalty of reprimand to the respondent for her indecorous conduct amid the altercation, especially given her obligation as a personnel officer to model proper behavior.
• Additionally, the complainant was ordered to show cause within ten (10) days why disciplinary action should not be initiated against her for her own participation in the disturbance.

Issue:

Determination of Provocation and Responsibility

• Whether the complainant’s actions in confronting the respondent contributed significantly to the escalation of the altercation.
• Whether the respondent’s subsequent actions, given her position as a government personnel officer, constituted a breach of expected decorum and proper conduct.

Appropriateness of the Disciplinary Measures

• Whether the reprimand imposed on the respondent was commensurate with her actions during the altercation.
• Whether the complainant should likewise be subject to disciplinary action given her role in provoking the disturbance.

Credibility and Weight of Evidence

• The reliability of the testimonies, particularly that of Mr. Cabrera, and how they help in determining the sequence of events.
• How conflicting accounts, especially between the complainant and the respondent, affect the final decision regarding disciplinary liability.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)