Castillo-Casiquin v. Cansino
REITERATIONFacts
The Antecedents: Complainant Amelita Castillo-Casiquin alleged that respondent Gregoria Figuerrez Cansino, a court stenographer, engaged in disgraceful and immoral conduct by marrying and cohabiting with the complainant's husband, Villamor Casiquin. The complainant stated she married Villamor in 1977, and in 1983, discovered he was cohabiting with the respondent. The respondent subsequently married Villamor in 1984, despite knowing he was already married to the complainant, and had two children with him. Procedural History: The respondent, in her comment, admitted to the marriage and cohabitation but claimed good faith, asserting Villamor had misled her about his marital status. However, she later learned the truth in July 1985 and separated from him. The Office of the Court Administrator (OCA) reviewed the complaint and comment, finding the respondent guilty of disgraceful and immoral conduct. The OCA noted that Villamor had not concealed his marital status and recommended a suspension of six months and one day, considering it was the respondent's first offense. The Petition: This case reached the Supreme Court as an administrative matter (A.M. No. P-06-2240) following the OCA's report and recommendation. The Supreme Court affirmed the OCA's findings, agreeing that contracting marriage and cohabiting with a married person constitutes disgraceful and immoral conduct, especially for judicial personnel. The Court found the respondent guilty of the charge and imposed the recommended penalty of suspension for six months and one day without pay, with a stern warning against future transgressions.
Issue(s)
Whether respondent Gregoria Figuerrez Cansino is guilty of disgraceful and immoral conduct by contracting marriage and/or cohabiting with someone who is already married. Whether respondent's claim of good faith in marrying and cohabiting with a married man negates her administrative liability, considering her knowledge of his existing marriage.
Ruling
The Supreme Court found respondent Gregoria Figuerrez Cansino guilty of disgraceful and immoral conduct and suspended her for six months and one day without pay. She was sternly warned that repetition of the same or similar act would be dealt with more severely.
Ratio Decidendi
On the issue of whether respondent Gregoria Figuerrez Cansino is guilty of disgraceful and immoral conduct: The Court held that contracting marriage and/or cohabiting with someone who is already married constitutes disgraceful and immoral conduct. This is considered a grave offense that cannot be countenanced by the Court. Such an act manifests a deliberate disregard for the sanctity of marriage, which is an inviolable social institution protected by the Constitution and the law. The Court emphasized that this perversion is especially egregious when committed by judicial personnel, who are tasked with the administration of justice and the laws of the land. The respondent's actions directly violated Section 52(A)(15) of the Uniform Rules on Administrative Cases in the Civil Service, which classifies disgraceful and immoral conduct as a grave offense with corresponding penalties. On the issue of whether respondent's claim of good faith in marrying and cohabiting with a married man negates her administrative liability: The Court rejected respondent's claim of good faith. The Office of the Court Administrator (OCA) found that Villamor Casiquin, the complainant's husband, never concealed his marital status from the respondent. Since the respondent knew all along that Villamor was married to the complainant, she should not have entered into a marriage with him or cohabited with him. Her purported belief that the marriage was fake was insufficient to establish good faith in the context of administrative liability for immoral conduct. The confession by Villamor regarding his real name only occurred after their second child was born, and the respondent left him thereafter, indicating that her initial actions were taken despite knowledge of his existing marriage.
Main Doctrine
Contracting marriage and/or cohabiting with someone who is already married constitutes disgraceful and immoral conduct, a grave offense that cannot be countenanced, especially when committed by judicial personnel.