Case Digest (A.M. No. P-05-2100)
Facts:
The case before the Supreme Court involves Lourdes S. de Mateo, a Clerk III at the Municipal Trial Court in Cities (MTCC) located in Koronadal City, South Cotabato. Over the course of a single year, de Mateo faced multiple anonymous complaints alleging grave misconduct, dishonesty, and falsification. The complaints accused her of routinely being tardy—reporting to work between 10:30 a.m. and 12:00 noon—while manipulating her Daily Time Records (DTRs) to reflect an 8:00 a.m. start time. Furthermore, the complaints indicated that her absences were not accurately documented in her DTR. Additionally, allegations surfaced concerning her and her husband being involved in influence peddling or "fixing" activities, specifically linking them to a case involving Marbel Fit Mart, Inc. Another complaint, though unproven, suggested de Mateo was responsible for damaging a bundy clock.
In response, de Mateo submitted a Comment denying the charges on two occasions in 2000 and 2002. S
Case Digest (A.M. No. P-05-2100)
Facts:
- Several anonymous letter-complaints were filed against Lourdes S. de Mateo, Clerk III of the Municipal Trial Court in Cities (MTCC), Koronadal City, South Cotabato.
- The complaints charged her with falsification, dishonesty, and grave misconduct.
- It was alleged that while she habitually reported for duty between 10:30 a.m. and 12:00 noon, her Daily Time Records (DTRs) falsely indicated an 8:00 a.m. reporting time.
- Additional allegations involved her failure to record her absences properly and her involvement in influence peddling associated with known “fixers” at the Hall of Justice.
- Specific references were made to her alleged involvement in the Marbel Fit Mart, Inc. case and an accusation concerning the destruction of a bundy clock using salt, although the latter was not proven.
Background and Allegations
- In her comments dated November 17, 2000, and October 7, 2002, respondent denied all charges.
- She claimed her implication in the case involving Diding Pregua was solely due to their friendship and asserted that the allegations were unsubstantiated.
- She also denied direct involvement in the preparation of Venus Pascua’s property bail bond in the Marbel Fit Mart case.
- The respondent maintained that the complainant’s motivations were driven by personal animosity and ill will.
Respondent’s Denials and Explanations
- Upon an order to investigate, Judge Oscar E. Dinopol conducted proceedings and found respondent liable for grave misconduct and falsification.
- The investigation focused on the period from October 11 to 25, 1999, noting discrepancies between actual time logs and the entries in the DTR.
- It was established that her habitual tardiness and an entire day’s absence were not properly reflected in the DTR, and on several occasions, her DTR was punched in by fellow employees.
- The investigation revealed her involvement in the falsification of documents relating to a bail bond, including the preparation of tax declarations, application documents, and changes enforced by correction fluid.
- Although there was insufficient evidence of her giving advance information to an accused for monetary gain, the direct participation in falsification was unmistakable.
Investigation and Findings by the Investigating Judge
- The OCA compared genuine documents with simulated ones, concluding that the falsification of records (i.e., tax declarations, certificates of real estate tax payments) could not occur without her knowledge and participation.
- The endorsement by then Judge Agustin T. Sardido, favoring her non-complicity, was deemed without merit based on documentary evidence.
- Her close association with known fixer Gloria “Diding” Pregua was highlighted, reinforcing her role in the allegedly anomalous activities of the Marbel Fit Mart case.
- The collective evidence pointed to her direct involvement in falsifying not only property bond documents but also her official DTR entries.
- Her failure to provide a satisfactory explanation for the discrepancies between her DTR and the Head Guard’s log further solidified the findings against her.
Office of the Court Administrator (OCA) Findings
Issue:
- The issue revolves around the conflict between the DTR entries reported by the respondent and those recorded by the Head Guard.
- The sufficiency of evidence supporting the allegation of falsification outside the period specifically investigated (October 11–25, 1999) is also questioned.
Whether the falsification of Daily Time Records constitutes dishonesty and is sufficient to warrant a finding of grave misconduct.
- The reliance on the Head Guard’s discrete log contrary to the DTR entries is a critical point.
- The role and reliability of submitted evidence such as witness testimony (i.e., Lydia Jayme’s statement) and unauthenticated handwritten notes are examined.
Whether the available evidence, including unauthenticated documents and uncorroborated witness statements, is enough to establish the respondent’s direct involvement in the falsification of official documents.
- This includes considering if mitigating factors or satisfactory explanations offered by the respondent were adequately addressed.
- The weight of the established doctrine on administrative proceedings and the requirement for substantial evidence is also examined.
Whether the imposition of dismissal with forfeiture of benefits is justified in light of the evidence of grave misconduct and falsification.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)