Case Digest (G.R. No. 239995)
Facts:
The case involves Rosa C. Gonzalbo-Macatangay (petitioner) and the Honorable Civil Service Commission (respondent). The events leading to this case began on September 5, 2002, when Marites L. Calivara filed a complaint-affidavit with the Civil Service Commission (CSC) against the petitioner. Marites alleged that the petitioner married her husband, Modesto Macatangay, Jr., on February 3, 1997, while Modesto was still married to her. This led to a criminal case for Bigamy filed against both the petitioner and Modesto in the Regional Trial Court (RTC) of Lucena City. They pleaded guilty, resulting in their conviction, which became final and executory on October 8, 2002.
In her defense, the petitioner claimed she was unaware of Modesto's existing marriage at the time of their marriage and that she was coerced into marrying him due to her pregnancy. She later learned of Modesto's previous marriage in April 1996. The CSC-NCR subsequently charged her with the administrati...
Case Digest (G.R. No. 239995)
Facts:
Position and Allegations
- Petitioner Rosa C. Gonzalbo-Macatangay held the position of Secretary in the Passport Division of the Department of Foreign Affairs (DFA).
- On September 5, 2002, Marites L. Calivara filed a complaint-affidavit before the Civil Service Commission (CSC), alleging that petitioner contracted a second marriage with Modesto Macatangay, Jr. on February 3, 1997, while Modesto was still married to Marites.
Criminal Case for Bigamy
- Marites filed a criminal case for Bigamy before the Regional Trial Court (RTC) of Lucena City.
- Petitioner and Modesto pleaded guilty, resulting in their conviction for Bigamy. The RTC Decision became final and executory on October 8, 2002.
Petitioner’s Defense
- Petitioner claimed she had no knowledge of Modesto’s prior marriage when she married him.
- She later learned of Modesto’s existing marriage in April 1996 but married him in February 1997 due to her pregnancy.
- A civil case in 1999 declared her marriage to Modesto void.
- In 2004, Modesto’s marriage to Marites was also declared null and void, after which petitioner and Modesto remarried in Tokyo, Japan.
Administrative Charge
- The CSC-NCR indicted petitioner for the administrative offense of Conviction of a Crime Involving Moral Turpitude (Bigamy).
- Petitioner argued that the complaint violated the prohibition against multiplicity of suits and the doctrine of res judicata.
CSC-NCR Ruling
- On June 19, 2014, the CSC-NCR found petitioner guilty and imposed the penalty of dismissal from service, along with accessory penalties.
Appeals
- Petitioner appealed to the CSC Proper, which affirmed the CSC-NCR’s decision.
- The Court of Appeals (CA) also affirmed the CSC’s ruling, holding that mitigating circumstances could not be applied to her case.
Issue:
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Ruling:
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Ratio:
Bigamy as Moral Turpitude
- Bigamy is a crime involving moral turpitude, and its commission reflects the offender’s character and moral fitness.
Indivisible Penalty
- The penalty of dismissal from service for Conviction of a Crime Involving Moral Turpitude is indivisible and cannot be mitigated by circumstances such as length of service or first offense.
Public Servant’s Integrity
- Public servants are expected to exhibit the highest sense of discipline and integrity, both in their official duties and personal conduct. Petitioner’s actions failed to meet this standard.
Case-by-Case Basis
- Mitigation of penalties is determined on a case-by-case basis, depending on the offense and factual circumstances. Petitioner’s case did not warrant mitigation.