Facts:

The case revolves around a complaint filed by a group of 41 complainants, namely Luz Alfonso, Nestor Almoguerras, Ernesto Aquino, and others, against Rose Marie Alonzo-Legasto, the Executive Judge of the Metropolitan Trial Court (MeTC) in Quezon City, along with Emelita Camaya and Remediosa "Baby" Garcia, employees at the Office of the Clerk of Court, MeTC-Quezon City. The complaint involves allegations of graft and corruption, grave abuse of authority, and other serious misconduct stemming from the alleged arbitrary transfer of the complainants—employees of the Quezon City government—with accusations of discrimination, favoritism, and malversation of public funds.

On August 16, 1993, Judge Legasto sent a letter to Mayor Ismael Mathay, Jr., returning 40 of the complainants to the Quezon City Government, claiming it was necessary to assess staffing needs in the Office of the Clerk of Court as part of efforts to streamline operations. Although the reassignment was roote

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Facts:

Parties and Nature of the Case

• Complainants: Forty-one (41) City Government employees of Quezon City, appointed by different city mayors under separate appointment papers, who rendered services in the Office of the City Mayor, particularly in support of the Metropolitan Trial Court (MeTC).
• Respondents:
• Judge Rose Marie Alonzo-Legasto – then Executive Judge of the MeTC, Quezon City.
• Emelita Camaya – Clerk of Court III of the Office of the Clerk of Court, MeTC.
• Remediosa “Baby” Garcia – Records Officer I of the Office of the Clerk of Court, MeTC.
• Charges Filed: Graft and corruption, rendition of an unjust interlocutory order, fraud against the public treasury, malversation of public funds, estafa, discrimination, favoritism, grave abuse of authority, and grave and serious misconduct.

Initiation of Administrative Personnel Reorganization

• On August 16, 1993, Judge Legasto authored a letter to Mayor Ismael Mathay, Jr. indicating the return of all but one of the 41 complainants from the Office of the Clerk of Court (OCC) to the Quezon City Government.
• The said letter cited:
• The need to maximize the use of resources and manpower.
• An observation by Vice Mayor Charito Planas, following a recent personnel survey, regarding an alleged overstaffing in the OCC.
• A purported plan to reorganize the OCC based on a reorganization scheme previously initiated during the tenure of former Executive Judge Guillermo Loja.
• Prior Consultation and Assessment:
• Prior to the letter, Judge Legasto conferred with then Clerk of Court Herman R. Cimafranca and respondent Camaya concerning reducing the workforce.
• A clandestine observation was conducted by a designated Victor Ala over a two-week period at the OCC, culminating in a confidential Aide Memoire critiquing the workplace decorum and overpopulation.

Implementation of the Transfer

• On August 17, 1993, Mayor Mathay issued Office Order No. 47 reassigning the 41 complainants (and two others) to different offices within the Quezon City Government.
• Nature of the Transfer:
• Although the transfers did not immediately reduce salary or benefits since the new offices were in close proximity, this permanent reassignment contravened existing rules limiting the re-assignment authority solely to the Court under specified administrative orders.
• After the transfers, Judge Legasto further ordered unit supervisors within the OCC to reassess personnel requirements vis-à-vis work output.
• Allegations Raised by Complainants:
• Accusations of conspiracy between Judge Legasto, Camaya, and Garcia in favoring national employees over City Government employees.
• Claims of arbitrary personnel removal, improper recording of attendance, and inappropriate practices regarding the presence of children in the office.
• Specific allegation that Judge Legasto doctored payroll records to fraudulently claim excess compensation for election-related work.

Alleged Falsification of Daily Time Records (DTR’s)

• Period Covered: The controversy involved three (3) sets of DTR’s allegedly covering:
• The latter half of December 1989.
• The entire months of January and February 1990.
• Respondent Garcia’s Defense:
• Claimed that she reported for work for part of December 1989 and subsequently availed of leave (first half of December and sick leave for the remaining period, citing her husband’s vacation and an asthma condition).
• Presented a certificate from the Office of the Court Administrator stating that no leave application was filed for the period and offered another set of DTR’s for comparison.
• Evidence Against Garcia:
• Copies of the allegedly falsified DTR’s (certified public documents) showed her attendance entries that conflicted with her explanations.
• Testimonies and comparisons to her standard signatures indicated a visible resemblance supporting the genuineness of the entries in the questionable documents.
• Additional Indications of Misconduct:
• Garcia’s failure to produce her authentic DTR’s and to satisfactorily explain discrepancies.
• An inference that the falsified records were intentionally used to cover up her prolonged absence.

Investigation and Procedural Developments

• The case was referred on March 8, 1995, to Executive Judge Alfredo J. Gustilo of RTC-Pasay City for investigation, with an initial recommendation of exoneration on January 18, 1996.
• Subsequent Directives:
• On August 21, 1996, the Court urged a more exhaustive investigation, emphasizing that all complainants and relevant witnesses be given their day in court to clear up the facts.
• Despite the availability of 41 complainants, only six were presented as witnesses, and many annexed documents in the complaint were not thoroughly examined.
• On February 25, 1998, the Court reiterated its directive for a deeper probe and additional evidence.
• Final Investigatory Developments:
• With the appointment of Judge Gustilo to the Sandiganbayan, Judge Lilia C. Lopez was designated to resume the investigation and complete the hearing within 90 days, eventually recommending the dismissal of charges against Camaya due to insufficiency of evidence.

Findings from the Court’s Examination

• Administrative Misconduct by Judge Legasto:
• Exceeded her authority by permanently transferring court employees—a power reserved exclusively to the Office of the Court Administrator.
• Failed to notify the Court of the changes, thereby compromising judicial administrative supervision and efficiency.
• Dishonesty of Respondent Garcia:
• Found responsible for the falsification of DTR’s covering December 1989 to February 1990.
• Her explanations were unsubstantiated and did not rebut the presumption based on certified copies of DTR’s.
• Lack of Evidence Against Respondent Camaya:
• Allegations involving bribery and unauthorized delegation of signing authority were inconsistent and not supported by credible evidence.
• Testimonies regarding the alleged P5,000 bribe varied significantly and ultimately failed to establish any corrupt intent.
• Other Non-sustained Allegations:
• Claims regarding inequitable treatment in attendance recording or child care were not corroborated by evidence.

Issue:

Authority and Legality of the Personnel Transfer

• Whether Judge Legasto exceeded her administrative authority by effecting a permanent transfer of 41 court employees, a power that should rest exclusively with the Office of the Court Administrator.
• Whether proper procedures, including prior notification to the Court and assessment of actual personnel needs, were observed before executing the reorganization.

Falsification and Dishonesty

• Whether the daily time records for December 1989, and January and February 1990, which were certified as public documents, were falsified by respondent Garcia to unjustly benefit from salary claims.
• Whether respondent Garcia’s explanations regarding her absences and the handling of her DTR’s are credible and consistent with the evidence on record.

Validity of Ancillary Allegations

• Whether the accusations against respondent Camaya regarding bribery, usurpation of authority, and manipulation of signing documents have sufficient evidentiary support.
• Whether the conduct observed—such as irregular attendance practices and discriminatory administrative measures—substantiates the claims of unfair treatment against City Government employees.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Excess of Authority and Violation of Administrative Orders

• The Court determined that Judge Legasto exceeded her powers by permanently transferring court employees—a move that infringed on the judicial administrative supervision mandated under Administrative Order No. 6 and Administrative Circular No. 30-91.

• The decision was anchored on the principle that any personnel assignment or reorganization within the judiciary must be coordinated with the Office of the Court Administrator to ensure the proper discharge of the judicial mandate.

Lack of Credible Explanation for Falsified DTR’s

• The falsified daily time records, being certified public documents, carried a presumption of authenticity which respondent Garcia failed to rebut with clear, strong, and convincing evidence.
• The similarities between the questioned signatures and Garcia’s standard signatures reinforced the finding of her responsibility for the falsification—a dishonesty that undermines public trust.

Insufficiency of Evidence Against Camaya and Other Allegations

• The Court observed that the allegations of bribery, usurpation of authority, and favouritism against Camaya were inconsistent, uncorroborated, and hinged largely on speculative testimony.
• The absence of a coherent narrative and conflicting testimonies left the charges against Camaya unproven, l

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