A.M. No. P-22-051 [Formerly OCA IPI No. 18-4831-P]. July 20, 2022
Ma. Lourdes A. Galit-Inoy, Complainant, vs. Melvin DC. Inoy, Court Stenographer III, Branch 266, Regional Trial Court, Taguig City, Respondent.

FACTS

Complainant Ma. Lourdes A. Galit-Inoy, the legal wife of respondent Melvin DC. Inoy, both Court Stenographers III in different branches of the RTC of Taguig City, filed an administrative complaint for immorality. She alleged that on February 16, 2018, she discovered romantic and intimate photographs, as well as a sex video, on their shared laptop, depicting respondent with a woman named Mary Ann. Complainant confronted respondent, who allegedly admitted it was him in the materials. She submitted these photographs as evidence of an illicit affair.
In his Comment, respondent denied the charges. He claimed the photographs were obtained without his consent from his Google account, violating his right to privacy, and were thus inadmissible. He asserted his relationship with Mary Ann was purely professional, as she was his mentor in a networking business. He denied being the person in the sex video screenshots, alleging they were taken from an adult website. Subsequently, complainant filed an Affidavit of Desistance, citing misunderstanding, but the OCA informed her she could not withdraw the complaint once lodged.

ISSUE

Whether respondent should be held administratively liable for disgraceful and immoral conduct.

RULING

Yes, the Supreme Court found respondent guilty of Disgraceful and Immoral Conduct, a grave offense under the amended Rule 140 of the Rules of Court. The Court adopted the findings of the Judicial Integrity Board (JIB) but modified the penalty. The Court ruled that substantial evidence, the required quantum of proof in administrative cases, was met. The intimate photographs submitted by complainant undeniably displayed a romantic and amorous relationship between respondent and Mary Ann, contradicting his claim of a purely professional association. The Court gave no credence to his defense, noting that mere denial, unsubstantiated by clear evidence, is a self-serving assertion deserving no weight.
The Court also rejected respondent’s argument regarding the inadmissibility of the evidence due to a purported violation of his constitutional right to privacy. It emphasized that administrative proceedings do not strictly adhere to technical rules of evidence; they are relaxed to achieve a just and speedy resolution. The act of a married person maintaining an intimate relationship outside of marriage constitutes disgraceful and immoral conduct, defined as behavior violating basic norms of decency and morality, indicative of moral indifference. Such conduct is morally reprehensible and tarnishes the integrity of the judiciary, whose personnel must uphold the highest standards of morality. Consequently, the Court suspended respondent from service for six months and one day without pay, with a stern warning that a repetition would be dealt with more severely.