Office of the Court Administrator v. Cruz
REITERATIONFacts
The Antecedents: The Office of the Court Administrator (OCA) received a letter from Executive Judge Jesus O. Angeles of the Regional Trial Court (RTC) of Dipolog City, informing it of an investigation conducted by the National Bureau of Investigation (NBI) on at least three incidents involving the falsification of court orders and the forgery of signatures of judges and a Branch Clerk of Court by respondent Edilberto N. Cruz, a Stenographer Reporter. Procedural History: The OCA filed an administrative complaint charging respondent with three acts of falsification. Respondent filed an answer denying participation. The case was referred for investigation, report, and recommendation to Executive Judge Wilfredo G. Ochotorena. After a full-blown investigation, the Investigating Judge submitted a report finding respondent guilty of grave misconduct and recommending dismissal. The Supreme Court reviewed the findings and evidence. The Petition: The OCA filed an administrative complaint against respondent Edilberto N. Cruz for falsification of court orders and forgery of signatures.
Issue(s)
Whether the respondent committed falsification of public documents and forgery. Whether the respondent's actions constitute grave misconduct, gross dishonesty, and conduct prejudicial to the administration of justice. Whether the respondent should be dismissed from the service.
Ruling
The Supreme Court resolved to DISMISS from the service respondent Edilberto N. Cruz for grave misconduct, gross dishonesty and conduct prejudicial to the administration of justice and the best interests of the public service, with forfeiture of all benefits, and with prejudice to re-employment in any branch or service of the Government, including government owned or controlled corporations.
Ratio Decidendi
On Whether the respondent committed falsification of public documents and forgery: The evidence preponderantly established that the respondent committed falsification in three instances. Regarding the first count, the respondent issued a Certificate of Finality below a purported Order dated July 6, 1990, bearing a forged signature of the retired Judge Pelagio R. Lachica. The case pertained to Branch 8, not Branch 9, and no motion for a new title was filed. The respondent presented the falsified order to the Register of Deeds, paid the registration fees, and had it registered. Regarding the second count, the respondent prepared a purported Order dated November 20, 1989, with a forged signature of Branch Clerk of Court Eyahiya S. Malon, and falsely represented that Judge Wilfredo C. Martinez signed it. The case number and subject matter did not exist in Branch 10. Regarding the third count, the respondent issued a Certification below an alleged Order dated August 30, 1985, purportedly issued by Judge Daniel B. Bernaldez. While this document was not presented to the Register of Deeds, the Investigating Judge found the respondent's signature on the certification to be genuine and authentic, and it bore a strong resemblance to his genuine signatures. The Court found that the respondent's claim of no participation was contradicted by evidence, including the comparison of his signatures and witness testimonies. On Whether the respondent's actions constitute grave misconduct, gross dishonesty, and conduct prejudicial to the administration of justice: The respondent's actions of falsifying court orders and forging signatures, thereby making it appear that judges issued lawful orders they did not, constitute grave misconduct, gross dishonesty, and conduct prejudicial to the administration of justice. By these misdeeds, he made it appear that judges had issued orders in due course, gave them the appearance of authenticity, and made a mockery of the trial court, tarnishing the integrity of the judges and deliberately making untruthful narrations of facts on papers passed off as public documents. Such conduct demonstrates a lack of integrity, uprightness, and honesty, which are essential for every employee of the judiciary. The Court emphasized that public office is a public trust and all public officers must serve with utmost responsibility, integrity, loyalty, and efficiency, and must be above suspicion. On Whether the respondent should be dismissed from the service: Given the gravity of the respondent's proven misdeeds, which constitute grave misconduct, gross dishonesty, and conduct prejudicial to the administration of justice, he is unfit for public trust and should not be allowed to continue serving in the Judiciary. The Court reiterated that it would never countenance any conduct that would diminish the faith of the people in the Judiciary. Therefore, dismissal from the service is the appropriate penalty, with forfeiture of all benefits and prejudice to re-employment in any branch or service of the government.
Main Doctrine
The proven misdeeds of a court employee, including falsification of public documents and making it appear that judges issued orders they did not, constitute grave misconduct, gross dishonesty, and conduct prejudicial to the administration of justice, warranting dismissal from the service.