Title
Aquino vs. Acosta
Case
A.M. No. CTA-01-1
Decision Date
Apr 2, 2002
Atty. Aquino accused Judge Acosta of sexual harassment, citing unwelcome physical contact. The Supreme Court exonerated him, ruling the acts as casual gestures, but admonished him for deportment.

Case Summary (A.M. No. CTA-01-1)

Respondent’s Denials

Judge Acosta denied any malice or lascivious intent, characterizing each kiss as a customary “beso-beso” greeting on festive occasions (e.g., Christmas, New Year, Valentine’s Day, legislative milestone). He maintained phone calls were work-related, not solicitations of sexual favors, and noted transparent glass dividers precluded private advances. He apologized by note after the final incident.

Investigation and Procedural History

Pursuant to an En Banc resolution, the Supreme Court assigned Justice Salonga to investigate. After neither party offered further evidence, memoranda were submitted. Justice Salonga’s January 9 report recommended dismissal for lack of convincing proof that respondent’s kisses constituted sexual harassment under R.A. 7877 or violated judicial ethical standards, but advised a warning to avoid conduct that could be misconstrued.

Findings of Fact by Investigating Justice

  1. Most kissing incidents occurred in public or festive contexts.
  2. Complainant’s reaction in some cases (reciprocating greetings, joining lunch) was inconsistent with typical harassment responses.
  3. Witness affidavits lacked direct observation of any lewd or malicious act.
  4. Complainant failed to establish that any kiss was a demand or condition affecting her employment or working conditions.
  5. The “beso-beso” practice was corroborated by multiple non-biased witnesses as customary among CTA personnel.

Legal Analysis under R.A. No. 7877

To constitute work-related sexual harassment, three elements must coexist:

  1. An authority or moral ascendancy in a work environment.
  2. A demand, request, or requirement of a sexual favor.
  3. Resulting adverse employment consequences or creation of a hostile work environment.

Here, while respondent held supervisory authority, complainant did not prove that any kiss was demanded as a sexual favor, nor did she show discriminatory treatment, impaired job rights, or an intimidating environment. Casual greetings fall outside the Act’s prohibitions.

Supreme Court Decision and Disposition

The Supreme Court

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