G.R. No. 172384 - Florentino vs. Supervalue, Inc.

The case involves Priscilla L. Hernando (Complainant) and Juliana Y. Bengson (Respondent), the latter serving as a Legal Researcher at RTC, Branch 104, Quezon City.
The administrative proceedings centered on allegations of misconduct by Bengson in connection with her involvement in facilitating land transfers.

On March 10, 2010, the Court rendered a Resolution finding Bengson guilty of Simple Misconduct.
The Investigating Judge and the Office of the Court Administrator (OCA) had recommended the imposition of a 30-day and one-day suspension based on the initial findings.
In a motion for reconsideration filed by Hernando, she argued that Bengson’s conduct—specifically, her act of offering to facilitate the processing of land transfer papers at the Bureau of Internal Revenue (BIR)—was prejudicial to the best interest of the service.
Hernando further requested restitution amounting to PhP76,000.00, which she characterized as an ajust debt given to Bengson.

After reviewing the records, including the report from the Executive Judge and the recommendation of the OCA, the Court reaffirmed Bengson’s complicity in the failed titling process of Hernando’s property.
Relying on the pronouncement in Largo v. Court of Appeals, the Court reevaluated the nature of the penalty imposed.
On March 28, 2011, the Court modified its earlier Resolution by transforming the penalty from a 30-day and one-day suspension to a suspension of six (6) months and one (1) day without pay.
The modified Resolution also maintained the order for Bengson to restitute PhP76,000.00 plus legal interest to Hernando, with interest computed starting from the year 2003.

The Court clarified that the suspension period completed pursuant to the March 10, 2010 Resolution would count as part of the total suspension imposed by the March 28, 2011 Resolution.
This means that the earlier period of suspension served was credited against the total duration of the revised six-month and one-day suspension.

Whether the initial 30-day and one-day suspension imposed under the Resolution dated March 10, 2010, was to be considered as distinct or as a continuation of the revised suspension order of six (6) months and one (1) day issued on March 28, 2011.

Whether Bengson’s act of facilitating land transfer papers falls under conduct prejudicial to the best interest of the service as analogized from the case of Largo v. CA, distinguishing between misconduct performed in an official capacity versus in a private capacity.

The propriety of ordering restitution of PhP76,000.00 (plus accrued legal interest) to the complainant given the findings of misconduct.