Case Digest (G.R. No. 211962) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Escandor v. People of the Philippines (G.R. No. 211962, July 6, 2020), petitioner Jose Romeo C. Escandor served as Regional Director of the National Economic and Development Authority (NEDA) Region 7 in Cebu City from August 16, 1992, until October 31, 2005. From July 1999 until November 2003, he allegedly made unwelcome sexual advances against his subordinate, contractual employee Cindy Sheila C. Gamallo, including grabbing her hands, embracing and kissing her on the forehead and cheek, groping her thigh, proposing dates, sending amorous Winpop and text messages, and presenting gifts of chocolates, wine and a bracelet. Gamallo testified that these acts created an intimidating, hostile work environment that adversely affected her emotional well-being and work performance. After Gamallo filed a Complaint-Affidavit on September 4, 2004, Escandor was charged by Information dated March 21, 2007 with violating Republic Act No. 7877 (the Anti-Sexual Harassment Act of 1995). On Octo Case Digest (G.R. No. 211962) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Positions
- Jose Romeo C. Escandor (Petitioner)
- Regional Director, National Economic and Development Authority (NEDA) Region 7, Cebu City (Aug. 16, 1992–Oct. 31, 2005)
- Cindy Sheila C. Gamallo (Private Complainant)
- Contractual employee, NEDA Region 7, UNICEF-assisted Fifth Country Program for Children (Mar. 1995–Dec. 2003)
- Allegations of Sexual Harassment
- Initial Incidents (July 1999–2000)
- July 1999: Escandor summoned Gamallo, apologized, then grabbed her hand, embraced, and kissed her forehead
- 2000 office meetings: verbal advances (“fallen in love,” asked on dates), groping her thigh, sending amorous Winpop messages
- Holiday Party and Continued Advances
- 2000 Christmas party: Escandor kissed her on the cheek, stared during her dance, gave gifts (chocolates, wine, bracelet)
- Ongoing unsolicited messages, threats to remove her from meetings when she did not respond
- Corroborating Testimony and Administrative Report
- Co-workers Lina Villamor, Rafael Tagalog, and Asst. Regional Director Sandra Manuel witnessed or learned of the harassment and assisted Gamallo
- Manuel reported the matter to NEDA Deputy Director General, prompting Escandor’s reprisal threats
- Defense of the Accused
- Escandor’s Denial
- Claimed office layout and presence of his wife would preclude private harassment
- Asserted all allegations were fabrications by disgruntled employees
- Alleged Conspiracy
- Presented John Louis Savellon as lone witness to an ouster plot by NEDA staff
- Lower Court Proceedings
- Information filed March 21, 2007 under RA 7877 (Anti-Sexual Harassment Act)
- Sandiganbayan Special Third Division Decision (Oct. 17, 2013)
- Found Escandor guilty beyond reasonable doubt; sentenced to six months’ imprisonment and ₱20,000 fine
- Sandiganbayan Resolution (Feb. 28, 2014) denied motion for reconsideration
- Petition for Review on Certiorari filed with the Supreme Court under Rule 45
Issues:
- Whether Escandor’s guilt for sexual harassment under RA 7877 was proven beyond reasonable doubt
- Whether the discrepancy in the alleged date of the Christmas party (2000 vs. 2002) violated Escandor’s right to be informed of the charge
- Whether the complaint was filed within the three-year prescriptive period under Section 7 of RA 7877
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)