G.R. No. 95523 - Gonzales y Rivera vs. Court of Appeals

The administrative case originated from a letter dated July 7, 2015, authored by respondent Ruel V. Delicana, Legal Researcher of the MTCC in General Santos City, South Cotabato – Branch 3.
In his letter, Delicana protested the designation of Mary Jane Ganer-Corpuz as Acting Clerk of Court, arguing that the appointment was improper since an internal consensus during the February 3, 2014 meeting had stipulated that an acting Clerk should be chosen from among the branch’s own staff.

Delicana maintained that Ganer-Corpuz, being an “outsider” to the branch, could not be impartial regarding his pending administrative complaint against her and others.
He asserted that her appointment as Acting Clerk of Court was executed without proper authority from Judge Alejandro Ramon C. Alano, and that his objections were grounded in a legitimate concern over the ensuing conflict of interest.
Additionally, Delicana filed an administrative complaint against Atty. Ma. Jasmine P. Lood and Ganer-Corpuz, further intensifying the internal dispute.

In response, Ganer-Corpuz, along with Atty. Lood and Ma. Hazel P. Sebial, filed an Affidavit of Complaint charging Delicana with Conduct Prejudicial to the Best Interest of the Service.
They alleged that Delicana, though the matter was internal and confined to their office, disseminated confidential documents including his protest letter, the administrative complaint, and the minutes of the office meeting to multiple external offices and officials.
The list of recipients was extensive and included high-ranking judicial and governmental personnel, alongside representatives of the Philippine Association of Court Employees (PACE) at various levels, thereby allegedly damaging the reputation of the complainants.

In his Comment, submitted in response to the Office of the Court Administrator’s (OCA) directive dated February 23, 2016, Delicana maintained that his objection was made in a lawful and legitimate manner.
He clarified that only the cover letter of the complaint and excerpts of the meeting minutes (which he described as neutral and non-malicious) were attached.
Delicana explained his rationale for sending copies to certain recipients, including sending one to Judge Santiago while Judge Alano was on leave, and following Judge Alano’s lead in circulating an inter-office memorandum regarding the designation of Ganer-Corpuz.

The OCA, in its memorandum dated January 23, 2017, recommended a one-year suspension for Delicana due to his conduct, asserting that his actions created an impression of harassment and were intended to humiliate and embarrass complainants.
Despite a motion to withdraw the complaint by Ganer-Corpuz, the case proceeded as the withdrawal did not remove the Court’s jurisdiction over matters related to judicial discipline.

Whether the filing of a motion to withdraw the complaint by one party (Ganer-Corpuz) divests the Court of jurisdiction in determining the veracity of the administrative charges.
The significance of the withdrawal in the context of the Court’s duty to uphold judicial propriety and public confidence.

Whether Delicana’s act of disseminating confidential internal documents constituted conduct prejudicial to the best interest of the service.
Determining if his actions amounted to simple misconduct under the Revised Rules on Administrative Cases in the Civil Service.

Evaluating the gravity of the offense in light of Delicana’s previous reprimands for similar conduct.
Balancing mitigating factors, such as Delicana’s long years of service and eventual reconciliation with Ganer-Corpuz, against the need to maintain the integrity and proper decorum of the judiciary.