In a consolidated administrative case, the Supreme Court addressed allegations of disgraceful and immoral conduct against Atty. Nelson B. Castillejos, Jr., a Clerk of Court, and Preciousa Castillo-Macapuso, a Social Welfare Officer, both employees of the Regional Trial Court. The Court found both parties guilty of engaging in an extramarital affair, thereby violating the ethical standards expected of court personnel. As a consequence, both were suspended for one year without pay, serving as a stern warning against future misconduct.

When Courthouse Doors Open to Personal Indiscretions: Examining Ethical Boundaries in the Judiciary

The case began with Preciousa Castillo-Macapuso filing a complaint against Atty. Nelson B. Castillejos, Jr., citing grave misconduct and immorality. Their relationship began during PACE meetings, eventually leading to intimate relations. Preciousa, separated from her husband, alleged that Atty. Castillejos misrepresented himself as single and later defrauded her by failing to file an annulment case despite receiving payment. In a twist, an anonymous complaint then surfaced against Preciousa, accusing her of immorality due to the affair. The intertwined nature of these complaints led to their consolidation, aiming to uncover the truth and ensure accountability.

At the heart of this case lies the concept of **immoral conduct**, legally defined as behavior so willful, flagrant, or shameless that it demonstrates indifference to community standards. The Supreme Court has clarified that such conduct must be ‘grossly immoral’ to warrant disciplinary action, implying it must be a criminal act or so unprincipled as to be highly reprehensible. The difficulty lies in determining what crosses the line into ‘grossly immoral conduct’, especially when evaluating whether a lawyer or court employee is unfit to continue in their professional capacity.

Quoting the Supreme Court in Ventura v. Samson, the Court has explained:

immoral conduct involves acts that are willful, flagrant, or shameless, and that show a moral indifference to the opinion of the upright and respectable members of the community. It is gross when it is so corrupt as to constitute a criminal act, or so unprincipled as to be reprehensible to a high degree, or when committed under such scandalous or revolting circumstances as to shock the community’s sense of decency.

In this instance, Atty. Castillejos admitted to the affair, yet characterized it as merely based on mutual lust and desire. The Court, however, deemed his actions as a clear demonstration of gross immorality and disregard for the lawyer’s oath and the **Code of Professional Responsibility (CPR)**. The fact that he was married further aggravated his misconduct, highlighting a blatant disregard for the sanctity of marriage and family.

Extramarital affairs by lawyers are considered a direct affront to the sanctity of marriage and the family. Good moral character is a prerequisite for admission to the Bar and a continuing requirement for remaining in the legal profession. The CPR explicitly states:

Rule 1.01 — A lawyer shall not engage in unlawful, dishonest, immoral or deceitful conduct.

This provision underscores that lawyers are expected to uphold the law and serve as exemplars of ethical behavior. Their responsibilities extend beyond merely avoiding legal trouble; they must actively maintain the rule of law.

Under the **Revised Uniform Rules on Administrative Cases in Civil Service**, disgraceful and immoral conduct carries a penalty of suspension for six months to one year for the first offense, and dismissal for the second offense. Despite Atty. Castillejos expressing remorse and attempting reconciliation with his wife, the Court found that his past actions could not be ignored without consequence.

Preciousa, too, was found guilty of the same infraction. As a married individual engaging in an affair with Atty. Castillejos, she also violated the ethical standards expected of court employees. The Court questioned her claim of ignorance regarding Atty. Castillejos’ marital status, considering his prominent position in the RTC of Cauayan City, Isabela. Her abusive text messages to Atty. Castillejos and his wife further demonstrated her erratic behavior, contributing to the finding of disgraceful and immoral conduct.

The Supreme Court emphasized the constitutional recognition of the sanctity of marriage and the need for judicial personnel to uphold moral righteousness and uprightness. Citing Concerned Employee v. Mayor, the Court stated that acts of having sexual relations with a married person constitutes disgraceful and immoral conduct and is especially egregious if committed by judicial personnel.

As the Court noted:

Time and again, it has been stressed that while every office in the government is a public trust, no position exacts a greater necessity for moral righteousness and uprightness from an individual that is part of the Judiciary. Indeed, the image of a court of justice is reflected in the conduct of the personnel who work thereat, from the judge to the lowest of its personnel.

The Court underscored that court employees must adhere to exacting standards of morality and decency, both professionally and privately, to preserve the integrity of the judiciary. There is no separation between public and private morals for court personnel.

What was the central issue in this case?	The central issue was whether Atty. Castillejos and Ms. Macapuso committed acts of disgraceful and immoral conduct by engaging in an extramarital affair, thus violating the ethical standards expected of court employees.
What is considered “immoral conduct” according to the Supreme Court?	The Supreme Court defines “immoral conduct” as behavior that is willful, flagrant, or shameless, showing indifference to the opinion of respectable community members, and that is considered grossly immoral if it constitutes a criminal act or is highly reprehensible.
Why is moral character important for lawyers and court employees?	Good moral character is a prerequisite for admission to the Bar and a continuing requirement for remaining in the legal profession. Court employees are also expected to uphold moral righteousness and uprightness to preserve the integrity and image of the judiciary.
What penalties can be imposed for disgraceful and immoral conduct?	Under the Revised Uniform Rules on Administrative Cases in Civil Service, the penalty for disgraceful and immoral conduct is suspension for six months to one year for the first offense, and dismissal from service for the second offense.
What was the basis for the Supreme Court’s decision?	The Supreme Court based its decision on the admission of the extramarital affair, the violation of ethical standards, and the need to uphold the integrity of the judiciary, as well as the provisions of the Code of Professional Responsibility and the Revised Uniform Rules on Administrative Cases in Civil Service.
What was the significance of the anonymous complaint filed against Preciousa Castillo-Macapuso?	The anonymous complaint expanded the scope of the investigation to include Ms. Macapuso’s role in the affair, leading to the consolidation of both complaints and ensuring that both parties were held accountable for their actions.
What is the Code of Professional Responsibility (CPR)?	The Code of Professional Responsibility (CPR) is a set of ethical rules that governs the conduct of lawyers in the Philippines. It outlines their duties to the court, to their clients, and to the public.
How does the Supreme Court view extramarital affairs involving judicial personnel?	The Supreme Court views extramarital affairs as offensive to the sanctity of marriage, the family, and the community. Such conduct is considered a deliberate disregard of marital vows, and is especially egregious when committed by judicial personnel.

This case serves as a reminder of the high ethical standards expected of those working in the judiciary. The Supreme Court’s decision underscores the importance of maintaining moral integrity both in and out of the workplace, highlighting that those who fail to meet these standards will face appropriate disciplinary action.

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: PRECIOUSA CASTILLO-MACAPUSO v. ATTY. NELSON B. CASTILLEJOS, JR., A.M. No. P-19-3985, July 10, 2019