Scribd Logo
Upload

Welcome to Scribd!

  • 489 views

    Mollaneda v. Umacob

    Uploaded by

    Troy San Mar
    Arnold Mollaneda, a school superintendent, was accused of sexually harassing Leonida Umacob, a teacher, in his office. Umacob reported the incident to the police and filed administrative complaints with the Civil Service Commission (CSC) and the Department of Education. The CSC found Mollaneda guilty, which was affirmed by the Court of Appeals. Mollaneda appealed to the Supreme Court. The Supreme Court found that Umacob was not guilty of forum shopping by filing in multiple venues. It also held that dismissing the criminal case did not require dismissing the administrative case, as they have different evidentiary standards. The CSC's finding of guilt was upheld.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOC, PDF, TXT or read online from Scribd

    Mollaneda v. Umacob

    Uploaded by

    Troy San Mar
    489 views2 pages
    Arnold Mollaneda, a school superintendent, was accused of sexually harassing Leonida Umacob, a teacher, in his office. Umacob reported the incident to the police and filed administrative complaints with the Civil Service Commission (CSC) and the Department of Education. The CSC found Mollaneda guilty, which was affirmed by the Court of Appeals. Mollaneda appealed to the Supreme Court. The Supreme Court found that Umacob was not guilty of forum shopping by filing in multiple venues. It also held that dismissing the criminal case did not require dismissing the administrative case, as they have different evidentiary standards. The CSC's finding of guilt was upheld.

    Original Description:

    Case Digest

    Copyright

    © Attribution Non-Commercial (BY-NC)

    Available Formats

    DOC, PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    Arnold Mollaneda, a school superintendent, was accused of sexually harassing Leonida Umacob, a teacher, in his office. Umacob reported the incident to the police and filed administrative complaints with the Civil Service Commission (CSC) and the Department of Education. The CSC found Mollaneda guilty, which was affirmed by the Court of Appeals. Mollaneda appealed to the Supreme Court. The Supreme Court found that Umacob was not guilty of forum shopping by filing in multiple venues. It also held that dismissing the criminal case did not require dismissing the administrative case, as they have different evidentiary standards. The CSC's finding of guilt was upheld.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    489 views2 pages

    Mollaneda v. Umacob

    Uploaded by

    Troy San Mar
    Arnold Mollaneda, a school superintendent, was accused of sexually harassing Leonida Umacob, a teacher, in his office. Umacob reported the incident to the police and filed administrative complaints with the Civil Service Commission (CSC) and the Department of Education. The CSC found Mollaneda guilty, which was affirmed by the Court of Appeals. Mollaneda appealed to the Supreme Court. The Supreme Court found that Umacob was not guilty of forum shopping by filing in multiple venues. It also held that dismissing the criminal case did not require dismissing the administrative case, as they have different evidentiary standards. The CSC's finding of guilt was upheld.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 2

    ARNOLD P. MOLLANEDA vs. LEONIDA C. UMACOB G.R. No. 140128 June 6, 2001 SANDOVAL-GUTIERREZ, J.

    : FACTS: Sometime Sept 7, 1994, Leonida Umacob, a public school, teacher went to the office of Mr. Rolando P. Suase to follow up her request for transfer to a different district. Therein, Arnold Mollaneda, school Division Superintendent, after entertaining her request hugged her, embraced her, kissed her nose and lip in a torrid manner, and mashed her breast. Mollaneda did these acts for several times then warned Umacob not to tell the incident to anybody. Umacob reported the incident to the police station and filed a complaint for acts of lasciviousness before the Municipal Trial Court. She also filed an administrative complaint as well with the Civil Service Commission - Regional Office XI, Davao City (CSC-RO XI). She furnished the Department of Education, Culture and Sports - Regional Office XI, Davao City (DECS-RO XI) a copy of her affidavit-complaint. A DECS investigating committee was formed, which later recommended to the DECS Regional Director "the dropping of the case" for lack of merit. Meanwhile, the case before the CSC was heard before Atty. Anacleto Buena, which hearing was attended by both parties and their counsel. CSC found Mollaneda guilty, which was affirmed by the Court of Appeals. Thus Mollaneda elevated the case to the SC. Mollaneda alleges that 1) Umacob was guilty of forum shopping, 2) He was denied due process, and 3) witnesses' testimonies were hearsay. Pending the SC case, the Municipal Trial Court dismissed the case of acts of lasciviousness. ISSUE:

    1) Whether or not Umacob was guilty of forum shopping; 2) Whether or not court erred in giving weight to witnesses' testimonies; and 3) Whether or not dismissal of the case in the MTC merits dismissal of the CSC. HELD: 1) No. With regard to the DECS and CSC, DECS was just furnished a copy of the complaint - it was not filed before the DECS. The resolution of DECS was just a recommendatory resolution. With regard to the filing of the case both in the CSC and the court, the case filed before the CSC is an administrative case while that before the court is a criminal case, thus it does not constitute forum shopping. 2) No. The witnesses' testimonies were offered not to prove its truth, but merely to prove that Umacob told the witnesses what transpired in the office. What was given more credence was the testimony of Umacob which was straight and replete with details consistent with human nature. 3) No. Long-ingrained in our jurisprudence is the rule that the dismissal of a criminal case against an accused who is a respondent in an administrative case on the ground of insufficiency of evidence does not foreclose the administrative proceeding against him or give him a clean bill of health in all respects. In dismissing the case, the MTC is simply saying that the prosecution was unable to prove the guilt of the respondent beyond reasonable doubt, a condition sine qua non for conviction because of the presumption of innocence which the Constitution guarantees an accused. However, in administrative proceedings, the quantum of proof required is only substantial evidence, which the court finds in this case.

    You might also like