A.M. No. P-24-140 - Gonzales vs. Geronimo

Complainant Antolyn D. Gonzales filed a Sinumpaang Salaysay dated April 25, 2022, before the Judicial Integrity Board (JIB) against respondent Dwight Aldwin S. Geronimo, Sheriff IV, Branch 121, RTC, Imus, Cavite.
Gonzales alleged violation of Canon I, Section 1 of the Code of Conduct for Court Personnel (CCCP) by Geronimo.

On April 22, 2022, Gonzales received a letter from the Tanza Post Office, addressed as from RTC, Branch 121, Imus, Cavite.
The envelope bore the indication "Private or Unauthorized Use on Non-Payment of Postage is Penalized by Fine or Imprisonment or Both."
Gonzales opened the letter, believing it was official court communication.
The envelope contained Geronimo's Verified Comment on a prior administrative complaint (JIB FPI No. 21-071-P) filed by Gonzales against Geronimo.
Gonzales verified with the local post office that Geronimo had been granted franking privilege upon representation that it was an official RTC transaction.

Gonzales averred that Geronimo unlawfully used his official position to gain unwarranted benefits by using the franking privilege.
On May 18, 2022, Atty. James D.V. Navarette, acting Executive Director of the JIB, required Geronimo to file a Verified Comment on the charges.
Geronimo filed his Verified Comment on July 4, 2022, claiming the use of the franking privilege was authorized and related to official duty in filing the administrative comment.
Geronimo further asserted that the complaint was baseless and a fishing expedition by Gonzales.

On July 5, 2023, Atty. Navarette submitted a Report finding Geronimo guilty of violating Presidential Decree No. 26 (on franking privilege), but recommended a penalty for simple misconduct.
The recommended penalty was a fine of PHP 18,000.00 with a stern warning.
The JIB, in its August 4, 2023 Report, affirmed the finding of simple misconduct and the recommended penalty.
JIB clarified that there was no clear evidence of bad faith or corruption, thus only simple misconduct liability applies, not criminal.

Misconduct defined as unlawful, willful acts in office.
Canon I, Section 1 CCCP prohibits court personnel from securing unwarranted benefits through official position.
Geronimo misrepresented the mail contents to obtain franking privilege, exempting postage payment.
Penalty for simple misconduct under Rule 140 of the Rules of Court includes fine or suspension; mitigating circumstances can reduce penalty.
First-time administrative liability for Geronimo enables mitigation of penalty to PHP 18,000.00 fine.
Clarified distinction between administrative and criminal liability: administrative cases require substantial evidence, criminal cases require proof beyond reasonable doubt.
Presidential Decree No. 26 is penal in nature; Court may not impose criminal penalties in administrative proceeding.
Previous cases holding employees liable for violation of Presidential Decree No. 26 are overruled respecting this distinction.
Geronimo found guilty only for simple misconduct, fined PHP 18,000.00, stern warning issued.

Whether respondent Dwight Aldwin S. Geronimo should be held administratively liable for simple misconduct for violating Canon I, Section 1 of the CCCP by using the franking privilege under Presidential Decree No. 26.

Whether the Court may impose criminal liability for violation of the Franking Privilege Law within an administrative case.