Title
Supreme Court
Abanag vs. Mabute
Case
A.M. No. P-11-2922
Decision Date
Apr 4, 2011
A court stenographer faced allegations of disgraceful conduct and forced abortion by a former partner. The court dismissed the complaint, ruling their consensual relationship between unmarried adults did not constitute grossly immoral behavior warranting sanctions.

Case Summary (A.M. No. P-11-2922)

Allegations of the Complaint

In her verified letter-complaint dated September 19, 2003, the complainant alleged that Mabute courted her and professed love, leading her to believe he would marry her. Consequently, she agreed to live with him, which resulted in pregnancy. However, during her pregnancy, Mabute allegedly tried to coerce her into undergoing an abortion and eventually abandoned her, leading to her depression and the loss of her child.

Respondent's Denial and Accusations

Mabute denied the allegations, describing them as fabricated and aimed at harassment. He claimed that Abanag was being manipulated by a co-worker, Norma Tordesillas, who had a vendetta against him following a reprimand. Mabute asserted that the complaint was not authored by Abanag but instead by Tordesillas, casting doubt on the authenticity of the allegations.

Investigation and Testimonies

The case was referred to Judge Carmelita T. Cuares for investigation, but after concerns about partiality, it was reassigned to Judge Esteban V. dela Peña and subsequently to Judge Agerico A. Avila. In their testimonies, both Mabute and Abanag acknowledged that they met through the Singles for Christ community and entered into a consensual relationship. Mabute refuted claims regarding any coercion for an abortion and attributed Abanag's miscarriage to her health issues, arguing that their relationship was voluntary and consensual.

Investigating Judge's Report and Recommendations

Judge Avila's report recommended the dismissal of the complaint against Mabute, highlighting that the personal affair between two consenting adults should not warrant administrative sanctions. The judge emphasized that there was no evidence to substantiate claims of forced abortion, and the relationship should not be construed as disgraceful under existing legal definitions.

Legal Definition of Immoral Conduct

The court articulated that immoral conduct implies willful, flagrant, or shameless behavior that disregards societal moral standards. For disciplinary action to be warranted, accusations must extend beyond simple immorality to gross immorality—acts that are criminal or egregiously unethical. Evaluating the case, the court found the relationship to be one between consenting adults without evidence of deceit or coercion.

Court's Conclusion

The court concluded that the relationship between Abanag and Mabute, despite its complications, did not equate to di

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