G.R. No. A.M. No. P-152 November 29, 1974
MARCIANA P. FLORES, complainant, vs. SOLEDAD V. GANADEN, respondent.

FACTS

Two administrative complaints were filed by Marciana P. Flores, a court clerk, against her co-employee, stenographer Soledad V. Ganaden, of the Court of First Instance of Zambales. The first complaint, dated July 18, 1973, charged respondent with grave oral defamation. This arose from an altercation in their office where Ganaden admitted to uttering defamatory remarks against Flores, specifically asserting that Flores had committed abortion when she was single. In her comment, Ganaden admitted the act but pleaded mitigation, claiming she lost her temper and was provoked by Flores.
The second complaint, dated August 21, 1973, charged Ganaden with libel and misconduct. This stemmed from Ganaden having filed official complaints against Flores in July 1973, reiterating the abortion allegation and further accusing Flores of falsifying her sick leave applications by stating the cause as influenza instead. Flores noted that the provincial fiscal had dismissed the falsification charge. Parallel criminal complaints for libel filed by Flores against Ganaden were pending before the Olongapo City court.

ISSUE

The primary issue is whether respondent Soledad V. Ganaden should be held administratively liable for her defamatory statements and conduct, and how the Court should treat the separate administrative complaint given the pending criminal case.

RULING

The Court found respondent administratively liable for the first complaint. Her own admission to uttering defamatory words during an office altercation rendered a formal investigation unnecessary. The Court emphasized that government personnel are bound by rules of proper and decorous behavior. Citing Atienza vs. Perez, the ruling stressed that “high-strung and belligerent behavior has no place in the government service,” where employees must act with self-restraint and civility at all times, even when provoked. While respondent cited provocation, this does not justify the misconduct. Accordingly, the Court administered the penalty of reprimand with a stern warning that a repetition would be dealt with severely.
Regarding the second complaint for libel based on the written charges filed by respondent, the Court provisionally dismissed it without prejudice. This decision was due to the pending criminal libel case between the same parties, which was sub judice. The administrative action was deferred to await the outcome of the criminal proceedings, as the facts and issues substantially overlapped. The dismissal is without prejudice to refiling should the criminal case result in a finding warranting further administrative action, provided the acts are not already covered by the reprimand issued for the oral defamation. A copy of the resolution was ordered entered in respondent’s personal record.