Case Digest (A.M. No. P-292)
Facts:
In the case of Atty. Isidro G. Arenas vs. Manuel Resultan, Sr., the complainant, Atty. Isidro G. Arenas, filed a letter-complaint addressed to the Chief Justice of the Supreme Court on November 25, 1982. He charged Manuel Resultan, Sr., the Clerk of Court of the City Court of San Carlos City, with two main allegations: (1) infidelity in the custody of public records and (2) discourtesy, inefficiency, and incompetence in the performance of official duties, which he claimed was conduct prejudicial to the best interest of the service. The first charge stemmed from the respondent's inability to locate the records of Criminal Case No. CC-875, entitled "People of the Philippines vs. Rodrigo de Guzman," despite repeated inquiries from Arenas, particularly regarding the regularity of the bail bond posted by the accused. The second charge involved an incident where Arenas alleged that Resultan treated him with disrespect and failed to assist him when he sought informatio...
Case Digest (A.M. No. P-292)
Facts:
Background of the Case: Atty. Isidro G. Arenas filed a letter-complaint against Manuel Resultan, Sr., Clerk of Court of the City Court of San Carlos City, alleging two charges: (1) infidelity of public records and (2) discourtesy, inefficiency, and incompetence in the performance of official duties, and conduct prejudicial to the best interest of the service.
First Charge: Infidelity of Public Records: Atty. Arenas alleged that Respondent Resultan could not locate the records of Criminal Case No. CC-875, entitled "People of the Philippines vs. Rodrigo de Guzman," despite repeated demands. This issue arose when Arenas inquired about the regularity of the bail bond posted by the accused.
Second Charge: Discourtesy and Inefficiency: Arenas claimed that when he attempted to verify the records of the criminal case to file the bail bond, Resultan displayed an arrogant attitude, neglected his inquiry, and showed disrespect towards him.
Respondent’s Defense: Resultan countered that on July 3, 1974, Atty. Arenas arrived at his office "strongly under the influence of liquor" and became aggressive when Resultan questioned why the accused, Rodrigo de Guzman, was required to post a bond. Resultan alleged that Arenas physically assaulted him, forcing him to flee and file a criminal complaint against Arenas. Resultan also stated that he had already been informed by a clerk, Mrs. Virginia Fernandez, that the records of Criminal Case No. CC-875 were missing before the incident. He claimed to have made exhaustive efforts to locate the records but was unsuccessful. The case proceeded with a reconstructed record, and the accused was tried, convicted, and served his sentence.
Investigation Findings: The Deputy Court Administrator and the Inquest Judge found that Resultan acted in good faith in reconstructing the records and that no damage was caused to the parties involved. The Inquest Judge recommended the dismissal of the complaint, noting that Arenas voluntarily desisted from prosecuting the case during the formal investigation.
Issue:
- Whether Respondent Manuel Resultan, Sr. is guilty of infidelity of public records for failing to locate the records of Criminal Case No. CC-875.
- Whether Respondent is guilty of discourtesy, inefficiency, and incompetence in the performance of his official duties.
- Whether Respondent should be held administratively liable for the loss of the records and his alleged misconduct.
Ruling:
The Supreme Court dismissed the administrative complaint against Manuel Resultan, Sr. but admonished him to exercise greater care in the custody of official documents. The Court warned that a repetition of the same or any similar act or omission would be dealt with more severely.
Ratio:
- Good Faith in Handling Records: The Court found that Respondent acted in good faith in reconstructing the records of the missing criminal case. Despite the loss of the original records, the case proceeded without prejudice to the parties, and the accused was convicted and served his sentence.
- Absence of Malice or Damage: There was no evidence of improper motive or damage caused by the loss of the records. The parties and their counsels acquiesced to the reconstitution of the records, and a fair trial was conducted.
- Duty of Care for Public Officers: As a public officer, Respondent is bound to exercise prudence, caution, and attention in the discharge of his duties. While the Court found no administrative liability, it admonished Respondent to be more vigilant in the custody of official documents and in supervising his subordinates.