A.M. No. CA-01-10-P - Floria vs. Sunga

The case involves interrelated administrative complaints among employees of the Court of Appeals.
Two separate complaints were filed: one against Alda C. Floria and another by Floria against Curie F. Sunga and Isidro A. Aperocho.

On August 5, 1999, Mrs. Badilla filed a letter-complaint with the Office of the Ombudsman alleging that Floria maintained an illicit relationship with Rodrigo Badilla, a former employee of the Court of Appeals, who was married to Celia Badilla.
In a sworn affidavit dated September 22, 1999, Rogelio Goyal charged Floria with falsification by alleging that she incorrectly indicated on her children’s certificates of live birth that she and Rodrigo Badilla were married on May 22, 1972 in Cabanatuan City.
Floria also faced an allegation of misrepresentation related to her academic credentials; she claimed to be a Master in Management graduate from the Technological University of the Philippines (TUP) even though the TUP Certification indicated that her application for graduation was still pending.
Floria admitted having two children with Rodrigo Badilla (born in 1974 and 1979) and also confessed to having engaged in an illicit relationship from 1974 until she severed ties in February 1980.

On September 8, 1999, a group of seven employees, including Sunga and Aperocho, filed a Manifesto with the Office of the Court Administrator (OCA).

The Manifesto alleged that Floria committed immorality, falsification, and misrepresentation.
It specifically charged Floria with fabricating her marital status on the birth certificates of her children and misleading the Selection and Promotions Board regarding her educational qualifications.

On September 17, 1999, Floria filed a complaint with the OCA against Sunga and Aperocho for “conduct unbecoming of a court employee,” docketed as OCA IPI No. 99-21-CA-P.
Floria alleged that Sunga and Aperocho were motivated by jealousy and malice; they intended to discredit her in order to prevent her nomination for the vacant position of Chief of the Information and Statistical Data Division (ISDD).

The earlier resolution dated February 12, 2001, adopted the Court Administrator’s recommendation.

It dismissed the complaint against Floria for charges of immorality, falsification, and misrepresentation “for lack of merit.”
It re-docketed Floria’s complaint against Sunga and Aperocho as a regular administrative matter and imposed a fine of P5,000.00 each on them along with a warning.

Evidence did not need to establish that Floria’s misconduct was ongoing to warrant administrative sanction.
Their motivation was not malice but a genuine concern for maintaining high moral standards among judiciary employees.
They emphasized that the stigma of an “adulterous affair” persisted and that Floria continued to benefit from the falsified documents regarding her children’s legitimacy.

Floria admitted to the illicit relationship with Badilla and the irregular entries in her children’s certificates of live birth.
The official documents, including the certificates bearing false marital entries and TUP certifications, formed the basis of evidence regarding falsification and misrepresentation.
There was a divergence in interpretations: while some evidence indicated that the relationship had ceased, the stigma and inherent dishonesty from such conduct remained central to the allegations.

Whether Floria’s conduct—specifically, her illicit relationship and the falsification on the birth certificates of her children—constituted an offense of immorality and dishonesty under administrative law.
Whether the fact that the relationship had ceased mitigated or negated the stigma of immorality attached to her conduct, especially given her status as a public employee.

Whether the complaint against Floria for immorality, falsification, and misrepresentation should be dismissed for lack of merit or sustained based on the evidence presented.
Whether Floria’s counter-complaint against Sunga and Aperocho holds merit in light of the allegations of jealousy and malice motivating their Manifesto.

Whether the motions for reconsideration filed by Sunga and Aperocho — challenging the earlier resolution — are admissible given the established doctrine that decisions exonerating a civil servant in administrative cases are generally not appealable by the complainant.
How the rule of non-reviewability applies to motions for reconsideration versus an appeal in cases involving administrative charges against judiciary employees.