G.R. No. 122866 - Nath vs. National Labor Relations Commission

Complainant: Atty. Pacifico Capuchino
Respondents: Eight court personnel of Municipal Trial Court in Cities (MTCC), Santiago City, Isabela, Branch 2

Atty. Capuchino was counsel for accused Marirose Valencia in Criminal Case No. II-4066 for violation of Batas Pambansa Blg. 22.
Valencia was convicted and ordered to pay P120,000 plus 12% interest.
Capuchino filed a motion for reconsideration; pending resolution, he attempted amicable settlement with private complainant Reynaldo Valmonte.

On May 9, 2001, at MTCC, Capuchino and Valencia met with Valmonte offering P120,000 to withdraw case, which was refused.
Valencia requested Tessie Duque, lone personnel left, to hold money temporarily; she agreed and issued a provisional receipt.
Court denied motion for reconsideration and issued Writ of Execution.
Valencia used provisional receipt to assert readiness to settle.

Respondents claimed Duque was unauthorized to hold litigants' money and reported to Judge Maxwell Rosete.
Duque filed motion for hearing instead of commenting.
September 24, 2002, hearing did not proceed; during inquiries, respondents Aspiras, Apolonio, Taguba taped conversations with Capuchino and Valencia without consent.
Recorded tapes used in letter-complaint to Chief Justice Hilario G. Davide, Jr., prompting investigation (A.M. No. P-05-1958).

OCA ordered redocketing as administrative matter and referral for investigation.
Investigation conducted; Judge Ruben R. Plata inhibited himself, case referred to Judge Fe Albano Madrid.
Judge Madrid found respondents not guilty of misconduct, suggesting complaint was retaliatory.
OCA disagreed, found taping as misconduct.
Some respondents exonerated; the case against others dismissed due to lack of evidence or retirement.
Only Taguba, Apolonio, Santiago remained charged.

Respondent Taguba previously charged with administrative offenses and suspended.
Apolonio and Taguba found guilty of gambling during office hours.

Whether the respondents committed grave misconduct by illegally recording conversations violating the Anti-Wire Tapping Act.
Whether the respondents’ conduct constituted administrative offenses warranting penalties.
Whether Atty. Capuchino had standing to file the complaint given the status of the criminal case.