Facts:

This administrative case arises out of a complaint filed against Emma Baldonado Curamen, serving as Court Interpreter I at the Municipal Trial Court of Rizal, Nueva Ecija. The complaint was lodged on March 6, 2007, by an anonymous source, accusing respondent Curamen of dishonesty and falsification of a public document, specifically regarding the registration of a child named Rica Mae Baldonado Curamen. The complaint indicated that Curamen misrepresented herself as the biological mother of the child in the local civil registry while, in reality, she was the child's maternal grandmother. Supporting documents included the alleged birth certificate of the child submitted by the complainant and the authentic birth records, which revealed the child's real name to be Rinea Mae Curamen Aquino. Rinea's legitimate parents, Olga Mae Baldonado Curamen Aquino and Jun Aquino, were identified as the actual biological parents of the child. Further accusations stated that Curamen cla

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Facts:

Background of the Case

• The case is an administrative proceeding brought against Emma Baldonado Curamen, Court Interpreter I of the Municipal Trial Court in Rizal, Nueva Ecija.
• The complaint arises from allegations of dishonesty and the falsification of a public document.

The Alleged Falsification of the Child’s Birth Certificate

• On 6 March 2007, the Office of the Court Administrator (OCA) received an anonymous complaint charging respondent with the falsification of a public document and simulation of birth.
• The complaint asserted that respondent misrepresented her relationship with a child by registering the birth of a purported child named Rica Mae Baldonado Curamen as her biological child, asserting that her husband was the biological father.
• The complainant presented a purported birth certificate as evidence to support the claim that respondent falsely claimed maternity, whereas it was alleged that respondent was in fact the child’s maternal grandmother.
• Evidence also included the original birth certificate of the child, which showed that the child’s true name was Rinea Mae Curamen Aquino and that the biological parents were Olga Mae Baldonado Curamen Aquino and Jun Aquino.

Verification and Corroborative Evidence

• Executive Judge Rodrigo S. Caspillo of the Regional Trial Court (Branch 24) of Cabanatuan City conducted a verification process.
• Judge Caspillo confirmed that Rinea Mae Curamen Aquino and Rica Mae Baldonado Curamen were the same child, establishing that the child was actually the respondent’s granddaughter.
• The real birth of the child was recorded on 27 November 2005 in the Civil Registry of Cabanatuan City, Nueva Ecija under Registry No. 2005-15495.
• Contrary to the original record, on 31 March 2006, respondent executed an affidavit for delayed registration and subsequently registered the child in Rizal, Nueva Ecija (Registry No. 2006-507) as her own child.

Respondent’s Explanation and Admission

• In her comment, respondent admitted that the true parents of the child were Olga Mae Baldonado Curamen Aquino and Jun Aquino.
• She explained that due to the financial incapacity of the actual parents—which were unemployed and dependent on her and her husband— the parents had proposed to have the child’s birth registered anew.
• Respondent maintained that there was no intent to conceal the child’s true filiation and that the practice was an extension of familial support commonly seen among Filipinos.
• Regarding the issue with her income tax return, respondent denied ever listing the child as an additional dependent.

OCA's Findings and Recommendations

• The OCA’s Report and Recommendation found respondent guilty of misconduct in connection to the alleged fabrication of the child’s birth certificate.
• The OCA noted that such falsification undermines public trust in court officials and the integrity of public documents.
• With respect to the income tax allegation, the OCA found no evidence that respondent made a false claim about dependents.
• The OCA recommended suspension from service for a period of six months and one day, among other administrative measures such as re-docketing the case and furnishing copies of the pertinent documents to the appropriate government offices.

Issue:

Whether Emma Baldonado Curamen falsified a public document by registering a child’s birth certificate under false pretenses.

• Determination of whether the supposed birth certificate of Rica Mae Baldonado Curamen was a deliberate misrepresentation of the child’s true identity and filiation.
• Evaluation of the respondent’s admission and justification for the creation of a duplicate or alternate birth record.

Whether there was any falsification or misrepresentation in respondent’s income tax return by unlawfully claiming the child as an additional dependent.

• Assessment of evidence provided by both parties regarding the listing of dependents in the income tax return.
• Consideration of the complainant’s bare allegations against the respondent’s provided documents showing her only claimed dependent was her 90-year-old father.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)