COMPLAINT-AFFIDAVIT

I, ATTY. SHERYL P. SUMAGUI, OIC-Director IV of the Investigation,

Enforcement, and Litigation Office, hereby depose and state that:

1. I am instituting this complaint against Analiza V. Muñoz (“Ms.

Ana”) in her capacity as Division Chief of the Investigation and
Enforcement Division for violation of the Revised Rules on Administrative
Cases in the Civil Service, specifically, Simple Neglect of Duty, Discourtesy
in the Course of Official Duties, Insubordination, and being notoriously
undesirable;

2. On 8 March 2023, I issued Memorandum No. IELO-2023-008:

Non-Observance of Proper Office Protocol, warning Ms. Ana that continued
violation of Office Protocols will be dealt with accordingly, under existing
rules and regulations and procedure on administrative matters due to a
notification from the Office of the Deputy Director General for Legal to my
Office that a document, specifically, IELO-IED-2023-0227-001 regarding
the Request for Approval of Mission Order for Motu Proprio Investigation
was forwarded directly to the ODDGL without the review of my Office
violating office protocols1. In response to the Notice of Warning issued to
Ms. Ana, she issued a Memorandum dated 10 March 2023 to answer
Memorandum No. IELO-2023-008: Non-Observance of Proper Office
Protocol2;

3. In the said Memorandum, Ms. Ana alleged that I have been

negligent and ignorant in issuing the Notice of Warning to her as the same
is allegedly without basis. Further, Ms. Ana also alleged that the receiving
and releasing of incoming and outgoing documents for the IED is not her
responsibility as Division Chief and that she is not responsible in keeping
track of the documents that another division released. Ms. Ana contended
that I falsely accused her that she did not submit the necessary IED one-
year plan and that I have been ignorant of the rules and processes
between the division within ARTA, as a public officer, Ms. Ana is bound, in
the performance of her official duties to observe courtesy, civility, and self
restraint in her dealing with others. In her Memoranda where improper
language has been used and has been sent to members of the IED and the
Deputy Director General for Legal and Deputy Director General for Admin
and Finance, it is shown that Ms. Ana failed to live up to these standards;

4. On separate instances, I have instructed Ms. Ana to observe the

complete staff work policy and submit complete documents for signing.

1
Annex “A”- Memorandum No. IELO-2023-008 dated March 8, 2023
2
Annex “B”- Memorandum dated 10 March 2023
However, the same has not been followed 34, her refusal to follow such
policy is tantamount to insubordination.

5. On separate instances, Ms. Ana disregarded the hierarchy of

positions when she bypassed the authority of the Office of the Director by
submitting a memorandum without my review to the Office of the Deputy
Director General for Legal prompting me to issue a Notice of Warning
against her for non-observance of Office Protocols.

6. Multiple errors in the submitted Investigation Reports are manifest

even with due correction from my Office 5, In this regard, Ms. Ana failed to
give proper attention to a task expected of an employee resulting from her
carelessness or indifference and as such guilty of Simple Neglect of Duty.

7. On separate instances, I have received separate complaints from

employees of the Legal Department regarding the attitude of Ms. Ana 6789, In
discussing notorious undesirability, the CSC prescribed a two-fold test on
whether it is common knowledge or generally known as universally
believed to be true or manifest to the world that the employee committed
the acts imputed against him/her and whether he had contracted the habit
for any of the enumerated misdemeanors, the general reputation of Ms.
Ana in the Legal Department as someone who is difficult to work with, her
discourteous conduct towards her supervisor and her staff shows that she
is notoriously undesirable.

PRAYER

WHEREFORE, in view of the foregoing, herein complainant most

respectfully prays unto this Honorable Office that respondent Analiza V.
Munoz of the IED be held liable for violating the Revised Rules on
Administrative Cases for Civil Service

IN WITNESS HEREOF, I have hereunto set my hand this 22 nd day of

March 2023, at Makati City, Philippines.

3
Annex “C” – Routing slip for IELO-IED-2023-0208-001 dated February 9, 2023
4
Annex “D” – Routing slip for IELO-IED-2023-0206-001 dated February 8, 2023
5
Annex “I” – Investigation Reports, IELO-2023-02-10-003, IELO-2023-02-10-004, IELO-2023-02-10-005, IELO-2023-
02-10-007, IELO-2023-02-10-008, IELO-2023-02-10-009, IELO-IED-2023-0213-001, IELO-IED-2023-02-13-005, IELO-
IED-2023-02-13-007, IELO-IED-2023-02-15-004, IELO-IED-2023-02-15-005, IELO-IED-02-16-001
6
Annex “E” – Letter-Explanation of Mr. Keirvin Anthony Viado
7
Annex “F” – Affidavit of Mr. Ferdinand Perena
8
Annex “G” – Affidavit of Atty. John Ramil V. Rabe
9
Annex “H” – Affidavit of Atty. Leonardo O. Tapia
 ___________________________
Atty. Sheryl P. Sumagui

SUBSCRIBED AND SWORN to before me this ________________ at Makati

City, Philippines, affiant exhibited to me her _____________ with No.
_______________ issued at _____________on __________________, as competent
proof of her identity.

Doc. No. ______

Page No. ______
Book No. ______
Series of 2020.