Facts:

The case involves two consolidated administrative matters concerning employees of the Office of the Clerk of Court (OCC) of the Regional Trial Court (RTC) in Manila. The first case, A.M. No. P-06-2110, was filed on April 20, 2002, by Cristeta D. Orfila, a Process Server, against Estifana S. Arellano, a Human Resource Management Officer II, for conduct unbecoming of a court employee. The second case, A.M. No. P-03-1692, was initiated on June 26, 2002, by Estifana and her husband, retired Judge Romulo Arellano, against Clerk of Court Jesus P. Maningas, Assistant Clerk of Court Jennifer C. Buendia, and Orfila, alleging graft, corrupt practices, and falsification of public documents.

The incident that sparked the complaints occurred on April 16, 2002, when Orfila visited Atty. Maningas to deliver suman for breakfast. During this visit, Arellano confronted Orfila regarding an unpaid loan of P10,000.00, leading to a heated argument. Arellano allegedly slapped Orfila, prompting At...

Facts:

Cristeta D. Orfila v. Estifana S. Arellano (A.M. No. P-06-2110)

• On April 16, 2002, Cristeta D. Orfila, a Process Server, went to the office of Atty. Jesusa P. Maningas, Clerk of Court of RTC Manila, to give her suman for breakfast.
• Estifana S. Arellano, a Human Rights Resource Management Officer II, barged into the office and demanded payment for a P10,000.00 loan Orfila had taken from her, including P2,000.00 in unpaid interest.
• A heated argument ensued, during which Arellano allegedly slapped Orfila on the left cheek. Witnesses Glenda Homeres and Ernesto Lacaba corroborated the slapping incident.
• Orfila sought medical attention and was diagnosed with swelling on her cheeks caused by slapping.
• Atty. Maningas instructed Atty. Jennifer C. Buendia, Assistant Clerk of Court, to investigate the incident. Arellano admitted to being carried away during the altercation.
• Orfila filed an administrative complaint against Arellano and a criminal complaint for slight physical injuries, slander by deed, and oral defamation.

Sps. Romulo and Estifana Arellano v. Jesusa P. Maningas, Jennifer C. Buendia, and Cristeta D. Orfila (A.M. No. P-03-1692)

• The Arellanos filed a counter-complaint against Orfila, Atty. Maningas, and Atty. Buendia, accusing them of various offenses, including falsification of public documents, graft, and corrupt practices.
• They alleged that Orfila falsified her birthdate in her Service Record and Personal Data Sheet to avoid compulsory retirement at age 65.
• They also accused Atty. Maningas of borrowing money from Arellano and failing to pay, and Atty. Buendia of conspiring with Orfila and Atty. Maningas to harass Arellano.
• Orfila denied the charges, claiming she had always believed her birthdate to be October 8, 1942, and that her birth records were destroyed during the Japanese occupation.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Misconduct and Usury: Arellano's actions of slapping Orfila and lending money at usurious rates violated the Civil Service Law and the standards of conduct expected of court employees.
2. Falsification of Documents: Orfila's falsification of her birthdate in official documents to avoid compulsory retirement constituted a grave offense under the Civil Service Law, warranting the forfeiture of her retirement benefits.
3. Borrowing from Subordinates: Atty. Maningas's act of borrowing money from a subordinate was a light offense under the Civil Service Law, meriting a fine.
4. Insufficient Evidence: The charges against Atty. Buendia and the additional charges against Atty. Maningas and Orfila were dismissed due to lack of substantial evidence.