A.M. No. 15-02-47-RTC - Re: Soliver C. Peras

A Complaint for Gross Insubordination and a Request for Psychiatric Evaluation was filed on November 5, 2014 by Executive Judge Soliver C. Peras of the RTC, Branch 10.
The complaint was directed against Catalina Z. Camaso, Utility Worker I of the Office of the Clerk of Court, RTC, based on her alleged acts of insubordination.

On September 10, 2014, Judge Peras issued a Memorandum detailing Camaso to Branch 10 to assist with filing, delivery, and the mailing of letters and correspondences.
Camaso did not report to Branch 10 nor did she provide any explanation for her non-compliance.

Judge Peras sent two additional memoranda directing Camaso to explain her failure to report, both of which went unheeded by her.
Judge Peras further alleged that Camaso exhibited strange and abnormal behavior, including:

Stating that she would not retire at age 65, on the grounds that she is a “national employee.”
Physically displaying abnormal behavior by sitting improperly on a chair—sitting on the backrest and resting her feet on the seat—thus endangering herself.

In view of her non-compliance and abnormal behavior, Judge Peras requested the Office of the Court Administrator (OCA) to conduct a psychiatric evaluation to ascertain Camaso’s fitness to work.
The evaluation was to determine whether an administrative investigation for gross insubordination should follow.

The OCA issued a Memorandum on September 10, 2015, directing that the matter be referred to Dr. Prudencio P. Banzon, Jr. for a neuro-psychiatric evaluation.
Dr. Banzon, along with contributions from a psychologist, conducted the evaluations and produced a Neuro-Psychiatric Evaluation Report (April 28, 2016) and a Psychological Report (April 5, 2016).
The evaluations concluded that Camaso was suffering from Delusional Disorder, Mixed Type (Grandiose and Persecutory), indicating a serious impairment in her mental functioning and her ability to maintain proper interpersonal relations at work.

Based on corroborative findings from both the psychologist and psychiatrist, the OCA issued a Memorandum on January 23, 2017, requiring Camaso to comment on why she should not be dropped from the rolls for mental unfitness.
In her handwritten Letter-Comment, Camaso argued that:

She was merely following an administrative order that does not require lower court employees to be assigned outside their job description.
She disputed Judge Peras’s jurisdiction over her, asserting her assignment to the RTC Library, which falls under the supervision of the OCA.

Ultimately, in a Memorandum dated December 6, 2017, the OCA recommended that Camaso be dropped from the rolls without forfeiture of her accrued benefits because her mental incapacity had impaired her efficiency and adversely affected her work environment.

The Revised Rules on Administrative Cases in the Civil Service (RRACCS), particularly Section 93, provided the legal basis for dropping employees who are physically or mentally unfit to perform their duties.
The provisions underscored the process whereby abnormal behavior substantiated by medical evaluation could warrant removal from service, while still preserving the employee’s benefits and eligibility for future re-employment in the government.

Whether Catalina Z. Camaso’s abnormal and uncooperative behavior, as corroborated by the psychiatric and psychological evaluations, constitutes grounds for her being dropped from the rolls for being mentally unfit to perform her duties.
Whether the administrative findings and recommendation under Section 93 of the RRACCS sufficiently support the decision to remove Camaso from her position without leading to forfeiture of her benefits or disqualification from future government re-employment.
Whether the procedural requirements for conducting a psychiatric evaluation and the subsequent administrative investigation were properly observed in this case.