Escandor v. People of the Philippines (G.R. No. 211962, July 6, 2020)

 Facts

Jose Romeo C. Escandor was the Regional Director of the National Economic and Development Authority (NEDA) Region VII. In 2004, he hired Cindy Sheila Cobarde-Gamallo as a contractual employee under the supervision of his office.

  • Cobarde alleged that Escandor made repeated unwelcome sexual advances toward her during her tenure, including:
  • Grabbing and holding her hand during meetings and office interactions
  • Attempting to kiss her on multiple occasions
  • Sending text messages expressing romantic feelings and making suggestive remarks
  • Touching her thigh during a car ride
  • Pressuring her into accompanying him to a resort under the pretext of work-related meetings

Despite her discomfort and repeated attempts to avoid these interactions, Cobarde felt compelled to comply due to Escandor’s authority and influence over her employment status. The incidents caused significant emotional distress, leading her to file a formal complaint.

The case was prosecuted under Republic Act No. 7877, or the Anti-Sexual Harassment Act of 1995, which prohibits sexual harassment in workplaces where power dynamics are abused.

Issues

  • Whether Escandor’s actions constituted sexual harassment under RA 7877.
  • Whether the power imbalance between Escandor and Cobarde established moral ascendancy sufficient to uphold the charge.

Held

The Supreme Court affirmed Escandor’s conviction for sexual harassment. The Court held that:

  • Sexual harassment exists when a superior uses their authority or influence to make unwelcome sexual advances.
  • Escandor’s repeated acts created a hostile and offensive environment for Cobarde, fulfilling the elements of the offense under RA 7877.
  • His position as Regional Director gave him moral ascendancy over Cobarde, and the persistence of his behavior clearly demonstrated abuse of that authority.
  • The victim’s resistance and testimony were deemed credible and consistent with the psychological behavior of harassment victims.

The Court emphasized that workplace sexual harassment undermines dignity and the right to equal opportunity, and public officials must be held to a higher standard of conduct.




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