G.R. No. 104726 - Yam vs. Court of Appeals

Initiation of the administrative case
The administrative case arose from an Affidavit-Complaint dated 4 July 2008 filed by Cristita L. Caya (Caya), Records Officer I, Office of the Clerk of Court, Metropolitan Trial Court (MeTC), Mandaluyong City, Branch 60.
The complaint targeted Rhodora A. Rantael (Rantael), Cashier I of the same court, and alleged:

Conduct unbecoming a court employee
Violation of the Code of Conduct and Ethical Standard for public officials and employees
Oppression and gross violence against a co-employee

The incident and Caya’s narrative
On 17 December 2007, while both were in the vicinity of the MeTC, Caya heard Rantael quarreling with a judge by telephone.
A co-employee, Joan Yerro, grabbed the phone from Rantael to prevent the situation from worsening.
Without apparent reason, Rantael directed her anger at Caya by:

As a result, Caya claimed she sustained physical injuries and emotional stress.

Medical Certificate dated 22 January 2008 of the attending physician who examined her for her physical injuries
The incident report Caya filed with the Mandaluyong City Police Station
Sinumpaang Salaysay dated 28 January 2008 and 31 January 2008, respectively, of Myrna G. Galope (Galope) and Ma. Lourdes G. Rodriguez, witnesses to the incident
Supplementary Affidavit dated 4 July 2008 of Galope, stating that Rantael admitted to her the reason for her actions

Rantael’s response and version of events
In her Comment dated 6 August 2008, Rantael disclosed that the incident was triggered by gossip allegedly spread by Caya and Arden Magsombol-Raosa (Raosa), Branch Clerk of Court of MeTC, Mandaluyong City, Branch 59, about Judge Myrna Lim-Verano (Judge Verano) of the Regional Trial Court, Muntinlupa City, Branch 205.
Rantael’s husband allegedly worked at the same court as Judge Verano.
Rantael alleged that Caya and Raosa made it appear that Rantael and her husband were spreading ugly rumors about Judge Verano.
Rantael admitted conversing with Judge Verano over the telephone on 18 December 2007, not 17 December 2007 as alleged by Caya.
Rantael alleged that Judge Verano accused Rantael as the source of the rumors.
Rantael denied the allegation that she was the source of the gossip and pointed to Caya as the real source.
Rantael acknowledged uttering invectives at Caya, explaining she felt hurt and wanted to respond to false accusations.
Rantael denied she initiated the physical assault and alleged that Caya slapped her first on the face.
Rantael admitted physically pulling Caya’s hair, but asserted it was her “fighting back” after Caya’s alleged slap.

Caya’s reply and the criminal case she filed
In her Reply dated 18 August 2008, Caya stated that Rantael’s Comment confirmed the charges that Rantael verbally abused and physically assaulted her.
Caya denied that she slapped Rantael on the face.
Meanwhile, Caya filed a criminal complaint for slander and physical injuries with the Office of the City Prosecutor (OCP) in Mandaluyong.

OCP action and subsequent challenge by Caya
In a Resolution dated 22 February 2008, the OCP indorsed the criminal complaint to the OCA, stating that:

The OCP reasoned that it was proper to refer the case to the Court to give due respect and recognition to the Court’s administrative authority over its employees.
In a Letter dated 26 June 2008 to the OCA, Caya questioned the OCP resolution and requested that the referral be set aside and the criminal case resolved on the merits.

OCA Report and Recommendation
On 20 March 2009, the OCA submitted its Report.
The OCA found both Caya and Rantael at fault for the incident within MeTC premises.
The OCA ruled that, because both admitted trading verbal barbs and inflicting physical injuries on each other, the incident sullied the image of the judiciary regardless of who started it.
As to the criminal complaint referred by the OCP to the OCA, the OCA found the referral improper, citing Maceda v. Vasquez.
The OCA explained that the mere fact that the parties in the criminal case were court personnel did not divest the OCP of authority.
The OCA recommended that:

The administrative matter be re-docketed as a regular administrative case against both Cristita L. Caya and Rhodora A. Rantael
Both Caya and Rantael be found guilty of misconduct and fined Php 1,000.00 each, with a warning of more severe action upon repetition
The OCP be directed to proceed with hearings on the criminal complaint for slander and physical injuries filed by Caya agai...(Subscriber-Only)

Administrative liability and propriety of findings
Whether Rantael was administratively liable for simple misconduct based on the incident and the parties’ accounts.

Liability and dismissal of the complaint against Caya
Whether Caya, as complainant and aggrieved party, could be held administratively answerable under the same incident.
Whether the complaint against Caya should be dismissed for lack of merit.

Due process in making Caya a respondent
Whether Caya’s right to due process was violated when she was made a respondent in the administrative case.