A.M. No. P-09-2632; June 18, 2010
Office of the Court Administrator vs. Cristita L. Caya and Rhodora A. Rantael

FACTS

This administrative case originated from a complaint filed by Cristita L. Caya, a Records Officer, against her co-employee, Cashier I Rhodora A. Rantael. Caya alleged that on December 17, 2007, within the premises of the Metropolitan Trial Court (MeTC) in Mandaluyong City, Rantael, after a heated telephone conversation with a judge, directed her anger at Caya. Rantael allegedly shouted curses, grabbed Caya by the hair, dragged her outside the office, and challenged her to a fight, causing Caya physical injuries and emotional distress. Caya supported her complaint with a medical certificate, a police report, and witness affidavits.
In her defense, Rantael admitted to a verbal altercation but claimed it was triggered by gossip allegedly spread by Caya about a judge. Rantael asserted she only fought back by pulling Caya’s hair after Caya slapped her first, a claim Caya denied. Meanwhile, Caya also filed a separate criminal complaint for slander and physical injuries with the Office of the City Prosecutor (OCP), which referred the case to the Office of the Court Administrator (OCA), citing respect for the Court’s administrative authority over its personnel.

ISSUE

Whether respondents Cristita L. Caya and Rhodora A. Rantael should be held administratively liable for their conduct during the altercation.

RULING

The Supreme Court found respondent Rhodora A. Rantael GUILTY of simple misconduct and imposed a fine of One Thousand Pesos (Php 1,000.00), with a stern warning. The complaint against complainant Cristita L. Caya was dismissed for lack of merit.
The Court’s ruling was based on the principle that court personnel must uphold the highest standards of conduct, as any disgraceful altercation between them tarnishes the judiciary’s integrity. While the OCA initially recommended sanctioning both parties, the Court, upon review, distinguished their culpability. Rantael’s admission to uttering invectives and engaging in a physical confrontation constituted misconduct, warranting administrative penalty. Conversely, the Court found the evidence insufficient to hold Caya administratively liable for initiating the fight, as Rantael’s counter-charges were not substantiated.
Furthermore, the Court clarified the jurisdictional issue on the criminal complaint. It directed the OCP of Mandaluyong to proceed with the criminal case for Slander and Physical Injuries, emphasizing that the pendency of an administrative case does not divest the regular prosecutorial bodies of their authority to investigate and prosecute criminal offenses. The two proceedings—administrative and criminal—can proceed independently, addressing different liabilities.