A.M. No. P-06-2256 - Gabriel vs. Ramos

Complainant: PO2 Patrick Mejia Gabriel.
Respondent: William Jose R. Ramos, Sheriff IV of the Regional Trial Court, Branch 166, Pasig City.

On August 22, 2005, Ramos allegedly destroyed personal belongings inside the house of Consolacion Dela Cruz Favillar, the mother of Jenelita Dela Cruz (with whom Ramos is in a common-law relationship).
After the destruction of property, Ramos reportedly indiscriminately fired a gun outside the said house.
Complainant contended that Ramos’ acts—both the extrajudicial use of force and his involvement in a long-term, scandalous common-law relationship—offended the moral sensibilities and decency expected of a public officer.

Ramos was charged with violations related to Alarms and Scandals and Violation of Domicile.
The complaint asserted that Ramos’ conduct, due to his involvement in a 15-year common-law relationship (while still married to another woman) and the incident involving the firearm, constituted immoral behavior and conduct unbecoming of a court personnel.
The complaint relied on Section 1, Article XI of the Constitution, which emphasizes that public office is a public trust and that public officers must lead lives of integrity, modesty, and accountability.

Ramos admitted to having a common-law relationship with Jenelita but denied that such a relationship, by itself, amounted to immorality, citing its longstanding nature and the existence of two children from the relationship.
He maintained that his actions at Consolacion’s house were merely related to the removal of personal belongings during a home transfer, not an act of unlawful domicile violation.
Additionally, Ramos argued that since the incident occurred outside his place of duty, the charges were not work-related but were instead aimed at harassing him due to his own pending criminal cases.

An Investigating Judge, Edwin A. Villasor, recommended that Ramos update his 201 file, and submit his marriage certificate along with the birth certificates of his children.
The Office of the Court Administrator (OCA) evaluated the case and found Ramos liable with regard to immorality, based on his cohabitation with Jenelita despite his subsisting marriage.
The OCA noted mitigating circumstances such as:

Ramos’ voluntary admission of cohabiting with Jenelita.
The fact that Ramos had been separated in fact from his lawful wife for a long time.
The common-law relationship, though scandalous, had gone on with apparent tacit acceptance by his wife and family, as indicated by the absence of a formal complaint from them.
No substantial evidence showed that the relationship adversely affected his official duties.

Ramos complied with procedural requirements by submitting his updated Personal Data Sheet, authenticated copies of his Marriage Contract, and the Certificate of Live Birth of his son.
Despite the criminal complaint for Alarms and Scandals having been dismissed on technical grounds, the administrative case continued because the standard of proof in administrative cases is that of substantial evidence rather than proof beyond a reasonable doubt.

Whether Ramos’ conduct in maintaining a long-term common-law relationship while still being married constitutes immorality and disgraceful behavior, thereby violating the ethical standards expected of a public officer.

Whether the act of indiscriminately firing a gun—irrespective of its apparent disconnection from his official duties—amounts to conduct unbecoming of a court personnel and is prejudicial to the best interest of the service.

Whether the dismissal of the criminal case on technical grounds affects or precludes the administrative proceedings, considering that administrative actions rely on a different evidentiary standard (substantial evidence).

Whether long-standing cohabitation, the existence of children, and argument of tacit tolerance by his estranged wife mitigate or exonerate Ramos from allegations of immorality and misconduct.