Dizon v. Campo
REITERATIONFacts
The Antecedents: Complainant Geraldine P. Dizon filed a Letter-Complaint against respondent Hiyasmin L. Campo, a Court Stenographer, for immorality. Complainant alleged that respondent was having an illicit relationship with her husband, Arnel T. Dizon, and that respondent was pregnant with his child. Complainant confronted respondent, who admitted the relationship and pregnancy, but continued the affair. Respondent later sent a text message to complainant stating her husband loved her and was willing to leave his family. Procedural History: The Office of the Court Administrator (OCA) initially recommended dismissal for lack of merit. However, complainant submitted additional evidence, including a certification of marriage between Arnel T. Dizon and respondent, and an application for marriage license. The OCA then referred the case to the Executive Judge of the RTC of Tarlac City for investigation. The Investigating Judge recommended a three-month suspension for immoral conduct. The OCA agreed with this penalty. The Court, however, found the recommended penalty insufficient. The Petition: The case reached the Supreme Court on review of the disciplinary action against respondent Hiyasmin L. Campo. The core issue was whether respondent was guilty of immorality and what penalty should be imposed. The complainant sought disciplinary action, while the respondent sought to resign. The Supreme Court reviewed the findings of the OCA and the Investigating Judge.
Issue(s)
Whether respondent Hiyasmin L. Campo is guilty of immorality. What is the appropriate penalty for the immoral conduct of respondent Hiyasmin L. Campo.
Ruling
The Court finds respondent Hiyasmin L. Campo guilty of immorality and imposes upon her the penalty of suspension for six (6) months and one (1) day without pay.
Ratio Decidendi
On Whether respondent Hiyasmin L. Campo is guilty of immorality: The Court affirmed the findings of immorality on the part of the respondent. The evidence showed that respondent engaged in an illicit relationship with Arnel T. Dizon, who was married to the complainant. Even assuming respondent was initially unaware of Arnel's marital status, she was put on notice when the complainant confronted her and pleaded with her to end the relationship for the sake of their children. Respondent's subsequent marriage to Arnel while his marriage to complainant was subsisting constituted immoral conduct. Her claim of ignorance was undermined by the fact that Arnel was a member of the Sangguniang Bayan, and she worked in the same Municipal Hall, making his marital status easily verifiable. The filing of an annulment suit after marrying Arnel did not extenuate her liability for the initial immoral act. On the appropriate penalty for the immoral conduct of respondent Hiyasmin L. Campo: The Court found the recommended penalty of three (3) months suspension by the OCA and the Investigating Judge to be insufficient. The Court held that the facts warranted the imposition of the minimum penalty prescribed by the Civil Service Law for disgraceful and immoral conduct, which is six (6) months and one (1) day of suspension. The Court noted that instead of rectifying her behavior after being confronted by the wife, respondent aggravated the situation by marrying the complainant's husband. Therefore, the Court imposed the penalty of suspension for six (6) months and one (1) day without pay.
Main Doctrine
Public employees, particularly those in the judiciary, are expected to maintain a high degree of morality and decency. Engaging in illicit relationships, especially with a married individual, constitutes disgraceful and immoral conduct, which is a ground for disciplinary action. The Court reiterated that ignorance of a paramour's marital status is not a valid defense if such status could have been easily ascertained, and that subsequent actions like filing for annulment do not negate the initial offense.