The Supreme Court ruled that administrative charges of immorality against a public employee must be supported by substantial evidence, not mere allegations or unsubstantiated claims. In this case, the complainant failed to provide sufficient proof of an illicit relationship between the respondent and another individual. This ruling emphasizes the importance of presenting concrete evidence to support accusations of misconduct, ensuring that administrative penalties are not imposed based on conjecture or hearsay. It serves as a reminder that in administrative proceedings, the burden of proof lies with the complainant to demonstrate the alleged misconduct with credible and convincing evidence.

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This case revolves around an administrative complaint filed against Myrna S. Lofranco, a Clerk III at the Regional Trial Court (RTC) in Digos City. Glanie Flores, along with several of her brothers-in-law, accused Lofranco of immorality, misconduct, and violating the Code of Conduct and Ethical Standards for Public Officials. The core of the accusation was that Lofranco, while still legally married, was allegedly having an illicit affair with Sabino Flores, the brother of the complainants. The complainants presented several pieces of evidence to support their claims, including an affidavit from Sabino’s son, a barangay blotter, and a private document where Lofranco purportedly signed as “Myrna Soledad Flores.”

Lofranco vehemently denied the accusations. She countered that her relationship with Sabino was purely professional, involving a joint business venture in mango cultivation. She further claimed that Sabino’s son’s affidavit was obtained under duress and that he had since recanted his statement. The investigating judge, after reviewing the evidence, found that the complainants failed to present substantial evidence to support their allegations. The judge noted that Sabino’s son’s initial affidavit was not properly identified, rendering it inadmissible as hearsay.

Building on this, the Supreme Court emphasized that in administrative cases, the burden of proof rests on the complainant. They must provide substantial evidence to support their allegations. Substantial evidence means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Here, the Court highlighted the lack of credible evidence presented by the complainants to substantiate their claims of immorality. The affidavit, the primary piece of evidence, was deemed inadmissible because the affiant did not testify to affirm its contents, violating the rule against hearsay evidence.

The Court also addressed the absence of solid proof for the charges of misconduct and violation of R.A. No. 6713, often referred to as the Code of Conduct and Ethical Standards for Public Officials and Employees. R.A. 6713 promotes a high standard of ethics in public service. Section 4 of the Act requires government employees to uphold principles such as professionalism, justness, integrity, and efficiency in their duties. Failure to do so may result in administrative repercussions, but only if the charges are adequately substantiated.

The Court cited settled jurisprudence that affidavits are generally considered hearsay unless the affiant is presented in court to testify and be cross-examined. As expressed in the case:

For this reason, affidavits are generally rejected for being hearsay, unless the affiant themselves are placed on the witness stand to testify thereon.

Considering the failure of the complainants to present sufficient evidence to prove the charges of immorality, misconduct, and violation of R.A. No. 6713, the Supreme Court affirmed the investigating judge’s recommendation to dismiss the administrative complaint against Lofranco.

FAQs

What was the key issue in this case?	The key issue was whether the administrative charges of immorality, misconduct, and violation of the Code of Conduct and Ethical Standards against a court employee were supported by substantial evidence.
What evidence did the complainants present?	The complainants presented an affidavit from the alleged paramour’s son, a barangay blotter, and a private document where the respondent purportedly used the alleged paramour’s surname.
Why was the affidavit of Sabino’s son deemed inadmissible?	The affidavit was deemed inadmissible because the affiant, Sabino’s son, was not presented in court to testify and affirm the contents of the affidavit, thus violating the hearsay rule.
What is the standard of proof required in administrative cases?	In administrative cases, the standard of proof is substantial evidence, meaning such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.
What is R.A. No. 6713?	R.A. No. 6713, also known as the Code of Conduct and Ethical Standards for Public Officials and Employees, sets forth the ethical standards that government employees must adhere to in the performance of their duties.
Who has the burden of proof in administrative cases?	The complainant has the burden of proving the allegations in the administrative complaint with substantial evidence.
What was the respondent’s defense in this case?	The respondent denied the allegations of an illicit affair and claimed that her relationship with Sabino was purely professional, involving a joint business venture in mango cultivation.
What was the final decision of the Supreme Court?	The Supreme Court dismissed the administrative complaint against the respondent, finding that the complainants failed to present substantial evidence to support their allegations.

This case underscores the judiciary’s commitment to upholding due process in administrative proceedings. It serves as a caution against levying serious accusations without the requisite evidence. Moving forward, this case highlights the importance of rigorously gathering and presenting concrete evidence to substantiate administrative complaints.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Glanie Flores, et al. vs. Myrna S. Lofranco, A.M. No. P-04-1914, April 30, 2008