G.R. No. 88211 - Marcos vs. Manglapus

Judge Guillermo P. Agloro, Presiding Judge of RTC-Malolos, reported irregularities in the petition for reconstitution of four transfer certificates of title docketed as LRC Case No. P-335-2011.
On May 17, 2012, Judge Agloro formalized his oral report and submitted a Private and Confidential Memo to then Executive Judge Renato C. Francisco, noting that although the LRC case had been raffled off to Branch 77, the records appeared in Branch 83.
The petition, which had sought to reconstitute the certificates, was granted by Branch 83 on November 4, 2011; however, the Office of the Clerk of Court (OCC) later refused registration of the entry of judgment on the ground that the case was actually raffled to Branch 77.
The anomaly put Judge Agloro in a predicament, as a pending motion for execution was still unresolved and the decision had not become final and executory.

In response to the reported irregularity, EJ Francisco issued a memorandum directing the OCC personnel and the OIC/Legal Researcher of Branch 77 to explain why the LRC case appeared in Branch 83 despite being raffled to Branch 77.
On July 5, 2012, the newly-appointed Executive Judge Ma. Theresa V. Mendoza-Arcega conducted her own investigation and referred the matter to the Office of the Court Administrator (OCA), forwarding case folders and affidavits from both Branch 77 and Branch 83.
The OCA then directed a more exhaustive investigation, leading to EJ Arcega’s detailed investigative report dated February 18, 2013.

EJ Arcega’s report corroborated Judge Agloro’s original allegation that the LRC case was raffled off to Branch 77 while records in Branch 83 showed discrepancies.

The records with Branch 77 contained the proper raffle sheet with signatures of the eight committee members and supporting documents like the summary of legal fees and assessment form from the Office of the Provincial Prosecutor of Bulacan.
In contrast, the records in Branch 83 lacked the summary of legal fees and had only three signatures—which were subsequently declared forgeries.

Judge Rolando J. Bulan (Branch 77) who highlighted that the petition had “N/A” in place of actual TCT numbers and directed petitioner Felicisima B. Buendia to provide legal basis for reconstitution.
Atty. Miguel Larida, who recounted receiving contradictory orders from Branch 83 and Branch 77, and stated that he had no clear knowledge of how the case had been misdirected.
Staff from the OCC who affirmed that after the raffle, the records were properly delivered to Branch 77 by the authorized utility worker, Marita M. Esguerra, a fact further acknowledged by Branch 77 personnel.
Personnel of Branch 83, notably Court Interpreter Leslie Burgos, Clerk-in-Charge Annaliza Santiago, and Court Stenographer Marissa Garcia, whose statements revealed a series of irregularities in handling the case records and the entry of judgment.

Leslie Burgos (OIC/Interpreter, Branch 83) initially discovered the anomaly when informed by Julieta Fajardo (Clerk-in-Charge) and noted that the LRC case was not recorded in the standard logbook for newly raffled cases.
Burgos reported the irregularity to Judge Agloro and conducted her own investigation, which led her to suspect connivance between Annaliza Santiago and Marissa Garcia.
Julieta Fajardo, upon discovering that the case was raffled to Branch 77 while being processed in Branch 83, explained that she refrained from filing an affidavit to avoid conflict with Garcia, whom she considered a friend.
Respondents Santiago and Garcia, in their respective comments, merely reiterated earlier affidavits without adequately addressing the irregularities or the allegations of complicity.

On March 5, 2014, the OCA Legal Office recommended that the investigation’s findings be treated as a complaint against Burgos, Fajardo, Santiago, and Garcia.
By July 28, 2016, the OCA recommended:

Re-docketing the administrative complaint as a regular administrative matter.
Dismissing the complaint against Burgos and, due to respondent Fajardo’s death, dismissing her charge—although judicial jurisprudence states that death does not automatically preclude administrative liability.
Finding Annaliza Santiago guilty of simple neglect of duty (later modified) and issuing a stern reprimand.
Holding Marissa Garcia liable for grave misconduct, serious dishonesty, and conduct prejudicial to the best interest of service, thereby recommending her dismissal with the forfeiture of retirement and benefits, except accrued leave credits, and perpetual disqualification from government re-employment.

Whether the irregular handling of the LRC case records—specifically, the misplacement and manipulation between Branch 77 and Branch 83—warrants administrative liability for the personnel involved.
Whether the actions (or inactions) of the respondents constituted gross deviations from standard courtroom procedures.

Whether the death of respondent Julieta Fajardo justifies a dismissal of the administrative case against her under the established jurisprudence.
The extent to which due process requirements are met for respondents who are no longer in service.

The degree of involvement of Court Interpreter Burgos, Clerk-in-Charge Santiago, and Court Stenographer Garcia in effecting the irregularities.
Whether their failures to adhere to established protocols—such as the proper logging of delivered records and the unauthorized issuance and cancellation of the entry of judgment—constitute simple neglect or amount to grave misconduct aggravated by dishonesty.