A.M. No. P-04-1784; April 28, 2004
Renato R. Mendoza vs. Antonia C. Buo-Rivera

FACTS

This administrative case originated from a letter-complaint filed by Antonia C. Buo-Rivera, a Court Stenographer III, against Renato R. Mendoza, a Sheriff. Rivera accused Mendoza of uttering scurrilous and insulting remarks against her on two occasions in 2002 within the Manila City Hall premises. Acting Executive Judge Enrico A. Lanzanas directed Mendoza to comment. Mendoza denied the allegations and submitted supporting affidavits from the alleged witnesses, Eduardo S. Divina and Atty. Carolina Peralta-Comon, who attested that the incidents did not occur. He also filed a countercharge, attaching a joint affidavit from three of Rivera’s co-employees portraying her as a habitual troublemaker who spreads false rumors.
Rivera subsequently filed a formal complaint with the Office of the Court Administrator (OCA). Initially, the OCA recommended dismissal due to Rivera’s lack of corroborating evidence. The Court initially dismissed Rivera’s complaint but, upon her motion for reconsideration which included a new affidavit from witness Gerardo Capulong, reconsidered and ordered a further investigation by Judge Lanzanas.

ISSUE

Whether respondent Antonia C. Buo-Rivera is administratively liable for making false accusations and sowing intrigues against a fellow court employee.

RULING

Yes, Rivera is administratively liable. In administrative proceedings, the burden of proof lies with the complainant, who must establish the allegations by substantial evidence. The Court found that Rivera failed to substantiate her charges against Mendoza. The falsity of her claims was evident from the countervailing evidence. The witnesses she initially cited, Divina and Atty. Peralta-Comon, categorically denied the incidents. While Capulong later executed an affidavit supporting Rivera’s second allegation, his credibility was rendered doubtful. He had initially refused to testify, and his change of heart was inadequately explained, partly motivated by an alleged menacing attitude from Mendoza after the initial dismissal.
Conversely, Mendoza’s countercharge was substantiated by substantial evidence. The joint affidavit from Rivera’s co-employees detailed her propensity for spreading malicious gossip and creating discord. Another witness, Sherry Cervantes, corroborated this pattern of behavior. Rivera offered no convincing evidence to rebut these specific and positive testimonies from her daily colleagues. Her act of lodging unsubstantiated accusations constitutes conduct unbecoming of a public servant, violating the standards of propriety and decorum required of all court personnel. Such behavior wastes judicial resources and undermines the integrity of the judiciary. Accordingly, the Court found Rivera guilty and imposed a fine of Five Thousand Pesos (₱5,000.00) with a stern warning.