Facts:

This case involves a sworn complaint filed by Atty. Joseph Anthony M. Alejandro (complainant) against Ms. Marilou C. Martin, a Legal Researcher and Officer-in-Charge Clerk of Court at the Regional Trial Court (RTC), Branch 268 in Pasig City (respondent). The complaint was lodged on October 27, 2006, and it centers on allegations of unexplained wealth and incompetence. The complainant accused the respondent of owning a piece of real estate situated at 2053 C. Cruz Malasaga Street, Pinagbuhatan, Pasig City, the value of which allegedly did not align with the income of the respondent and her family members, all of whom are employees of the RTC. Additionally, Alejandro alleged that the respondent was driving a new red Ford Lynx, registration number ZBD 191, which he claimed was inconsistent with her stated income. The absence of required Statements of Assets and Liabilities (SALs) for the years 2004 and 2005 further supported the complaint. The complainant pointed out a specific vio

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Facts:

Background of the Case

• Complainant: Atty. Joseph Anthony M. Alejandro filed a sworn complaint against Ms. Marilou C. Martin, the Legal Researcher and OIC-Clerk of Court of RTC, Branch 268, Pasig City.
• Charges: The complaint comprises two separate allegations against respondent:
• Unexplained wealth – alleging that respondent owned properties and a high-value vehicle that were inconsistent with her modest income.
• Incompetence – for failing to perform her duties properly, particularly the delayed transmittal of court records to the appellate court.

Allegations on Unexplained Wealth

• The house where respondent’s family resided, located at 2053 C. Cruz Malasaga Street, Pinagbuhatan, Pasig City, was claimed to be of considerable value.
• In addition, respondent was alleged to have been using a new red Ford Lynx (plate no. ZBD 191), acquired under circumstances or on terms that were deemed not justifiable by her salary.
• It was argued that such apparent disproportion between her income and the assets acquired is an indicia of corruption.
• Complainant further contended that respondent failed to file the required Statement of Assets and Liabilities (SAL) for the years 2004 and 2005, an obligation imposed on government employees.

Allegations on Incompetence

• The complainant asserted that as the clerk of court, respondent was mandated by Section 10, Rule 41 of the Rules of Court to transmit the records of cases to the appellate court within thirty (30) days after the perfection of an appeal.
• It was noted in SCA Case No. 2742 that the appeal was perfected on May 30, 2006; hence, the records should have been transmitted by June 30, 2006.
• Instead, the records were only transmitted on September 12, 2006, evidencing a significant delay.

Respondent’s Defense and Explaining Circumstances

• In her Comment, the respondent denied owning any property of substantial value, noting that she was still living with her parents.
• She clarified that the Ford Lynx was purchased by her father on an installment basis and was subject to a bank mortgage.
• Respondent also produced copies of her SAL for 2004 and 2005 to counter the allegation of non-filing.
• Regarding the delay in transmittal of records, she attributed it to the actions of the Clerk-In-Charge who was responsible for preparing essential documents (Letter of Transmittal, Table of Contents, and Index of Exhibits).
• Additionally, she contended that other equally important tasks in court monopolized her time, which contributed to the delay.

Findings by the Office of the Court Administrator (OCA)

• The OCA found that the charge of unexplained wealth against the respondent lacked sufficient substantiation by the complainant.
• It was determined that she had indeed complied with the SAL filing requirements.
• However, the OCA recognized that respondent was remiss in her duty regarding the transmittal of court records, warranting disciplinary action.
• The OCA recommended a fine of P3,000.00 along with an admonition to be more diligent in the performance of her responsibilities and a stern warning that a recurrence would be met with harsher sanctions.

Issue:

Sufficiency of Evidence for Unexplained Wealth

• Whether the allegations of unexplained wealth against the respondent were supported by substantial evidence or merely based on mere conjectures and suspicions.

Violation of Administrative Rules

• Whether the delay in the transmittal of the appellate records, in contravention of Section 10, Rule 41 of the Rules of Court, amounts to incompetence or negligence in the performance of her official duties.

Appropriate Disciplinary Measures

• What disciplinary action, if any, is warranted against an officer of the court who exhibits inefficiency in discharging her administrative functions and responsibility, particularly when the integrity and timely administration of justice are at stake.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)