A.M. No. 99-7-20-SC - Designating Branch 10 of the Regional Trial Court of Cebu City as a Special Court for Drug Cases

Atty. Isidro G. Arenas, formerly a judge of the City Court of San Carlos City, filed a letter-complaint addressed to the Chief Justice of the Supreme Court.
The complaint charged Manuel Resultan, Sr., the clerk of court of the City Court (San Carlos City, Branch X), with two counts:

Infidelity of public record
Discourtesy, inefficiency, incompetence, and conduct prejudicial to the interest of the service

On the first charge, Arenas alleged that Resultan failed to locate the records of Criminal Case No. CC-875 (“People of the Philippines vs. Rodrigo de Guzman”) despite repeated inquiries, particularly concerning the regularity of the bail bond posted by the accused.
On the second charge, Arenas contended that while he was verifying the records with an intention to file the bail bond, Resultan exhibited an arrogant attitude, refused to answer his inquiries with courtesy, and neglected his official duties.

According to Resultan’s account, on the day in question, two accused individuals, Juan Tuazon and Irineo de Guzman, visited the court upon the directive of the City Judge in connection with a violation of a city ordinance on drunkenness and inquiries regarding bail under the Laurel Law.
Shortly after, Atty. Arenas, who was observed to be strongly under the influence of liquor, arrived and questioned the requirement for a bail bond, leading to a verbal exchange.
Resultan allegedly redirected his inquiry to the accused by asking, “Why, did I tell you to post a bond?” which spurred resentment on the part of Arenas.
The situation escalated into a physical altercation wherein Arenas allegedly hit Resultan with fist blows and kicks, forcing the clerk to seek refuge at the police department and eventually leading to the filing of criminal charges.

Previously, Atty. Arenas had served as judge of the same court but had resigned amid the martial law era.
Resultan implicated eight personnel of the city court (including the current City Judge) who had access to court records, suggesting that the missing record might have been taken by or lost at the instance of the complainant.
It was already known that before the incident, the record for Criminal Case No. CC-875 was missing, and efforts had been made, including exhaustive searches, to locate it. Despite these efforts, the record remained unrecovered.
Despite the loss of the original record, the case was still tried on July 10, 1974, with subsequent hearings on August 8, 1974 (rescheduled to August 16, 1974), as the record had been reconstructed. Neither the parties nor their counsels complained about the reconstituted records.

Deputy Court Administrator Romeo D. Mendoza, with concurrence from Officer-in-Charge Arturo B. Buena, noted that when the case was investigated, Atty. Arenas failed to appear despite due notice, while Resultan appeared with counsel and cooperated with the investigation.
Resultan testified that upon being informed of the loss, he made “painstaking efforts” to locate the record and subsequently reconstructed it when the original could not be found.
The accused in Criminal Case No. CC-875 was tried, convicted, and served a sentence in the city jail of San Carlos.
Resultan was charged in connection with the loss of the records; however, an Assistant City Fiscal (Jaime O. Legario) exonerated him for lack of probable cause on October 16, 1974.
The Inquest Judge’s report confirmed that there was no evidence of any malicious intent, improper destruction, or willful neglect in handling the records. The reconstitution of the records and the absence of any resulting prejudice were central findings in the investigation.

Whether the actions (or omissions) of Clerk Resultan in the management and custody of court records amounted to infidelity of public record as charged by the complainant.

Consideration of whether the absence of the original record, despite exhaustive efforts to locate it, constituted a dereliction of duty.

Whether the behavior of Resultan, particularly in his interaction with Atty. Arenas during the incident, amounted to discourtesy, inefficiency, incompetence, and conduct prejudicial to the service.

Evaluation of whether his attitude and handling of inquiries were sufficiently negligent to warrant administrative disciplinary action.

Whether the lack of demonstrable damage or prejudice from the missing record, given its prompt reconstruction and the absence of complaints from involved parties, justified the dismissal of the administrative complaint.