A.M. No. P-04-1784 - Mendoza vs. Buo-Rivera

Antonia C. Buo-Rivera, Court Stenographer III of RTC Manila, Branch 55, initiated an administrative complaint against Renato R. Mendoza, Sheriff of RTC Manila, Branch 18.
The complaint stemmed from alleged unbecoming behavior by Mendoza as evidenced by certain scurrilous remarks directed toward Rivera.

On February 5, 2002, during a conversation with Legal Researcher Eduardo S. Divina at the hallway of the 4th floor of Manila City Hall, Mendoza allegedly shouted: "huwag kang maniwala diyan (referring to Rivera), niloloko ka lang niyan, binobola ka lang niyana."
On May 15, 2002, while Rivera was at the corridor adjacent to the office of RTC Manila, Branch 18, and reportedly looking for Gerardo M. Capulong (Court Stenographer III), Mendoza allegedly uttered: "bakit nandito na naman iyang putang-inang letseng babaeng iyan? Ikaw Gerald iwasan mo ang babaeng iyan at masamang impluwensiya iyan at baka ikaw mabuyo."

Rivera submitted her letter-complaint addressed to the Acting Executive Judge, Judge Enrico A. Lanzanas, who then instructed Mendoza to file his comment/answer.
In response, Mendoza denied the allegations and attached the affidavits of Eduardo S. Divina and Atty. Carolina Peralta-Comon, along with a joint affidavit from three co-employees of Rivera attesting to her reputation as a troublemaker and a habitual spreader of wild rumors.
Subsequently, while Judge Lanzanas was investigating the complaint, Rivera filed a formal complaint-affidavit with the Office of the Court Administrator (OCA) alleging conduct prejudicial to the best interest of the service.

The OCA, through Deputy Court Administrator Christopher O. Lock, initially recommended dismissal of Rivera’s complaint due to her failure to substantiate allegations with corroborative evidence—contrasted by Mendoza’s submission of evidence affirming his account.
On October 9, 2002, the Court adopted the OCA’s recommendation, dismissing the complaint for lack of merit.
Rivera then filed a motion for reconsideration on November 19, 2002, attaching the affidavit of Gerardo M. Capulong, who allegedly confirmed her claim regarding the second scurrilous remark.

On February 24, 2003, the Court set aside its earlier resolution and referred the complaint to Judge Lanzanas for further investigation, concurrently docketing Mendoza’s countercharge and consolidating it with the original complaint.
Subsequent hearings allowed for the reception of additional evidence, and Judge Lanzanas recommended that while the complaint against Mendoza be dismissed, Rivera should be found guilty.

The evidence revealed that the allegations against Mendoza were unsupported by credible testimony, with key witnesses (Eduardo Divina, Atty. Peralta-Comon, and Sherry Cervantes) negating the existence of the alleged scurrilous remarks.
Conversely, Rivera’s credibility was undermined by her failure to produce evidence to refute not only Mendoza’s defense but also the damaging testimonies of her co-employees.
Rivera was additionally found guilty of sowing intrigues, as supported by the joint affidavit of her co-employees and further corroborating testimonies detailing her habit of spreading wild rumors.
The OCA, after evaluating the recommendations of Judge Lanzanas, modified the penalty against Rivera by imposing a fine of Php 5,000 and warning her that any repetition of such questionable conduct would attract more severe sanctions.

Whether the testimony and documentary evidence presented by Mendoza sufficed to disprove the scurrilous remarks alleged by Rivera.
Whether Rivera’s own testimonies and supporting affidavits were credible and adequately substantiated her claims.

Whether the complaint against Mendoza was genuinely grounded on factual events or was a manifestation of Rivera’s personal vendetta, given her documented pattern of sowing intrigue and falsehoods.

Whether Rivera’s acts of making false accusations and disseminating gossip constitute conduct unbecoming of a public servant and warrant administrative sanction under the prevailing standards of the 1987 Constitution and R.A. No. 6713.