Case Digest (A.M. No. P-1551)
Facts:
Juanito Benaojan v. Mariano Lacson, A.M. No. P-1551, January 15, 1979, the Supreme Court En Banc, Guerrero, J., writing for the Court.In a sworn letter-complaint dated December 28, 1977, Juanito Benaojan (Interpreter and Special Deputy, Court of First Instance of Lanao del Norte, Iligan City) charged Mariano Lacson (Clerk, Court of First Instance of Lanao del Sur, Branch I, Marawi City) with falsifying his personal data/information sheets. Benaojan alleged that Lacson had misrepresented his educational attainments in two separate information sheets: one subscribed before Assistant Provincial Fiscal Benedicto A. Lagrosa on May 23, 1974, and another before Executive District Judge Moises Dalisay, Sr. on August 19, 1975.
The contested entries stated that Lacson graduated A.A. (Pre-Law) from the University of the East in 1952 and completed law studies at the University of Manila (with a 4th year Law graduation in 1966–1967 and a 1st year in Customs Administration at P.M.I.). Registrars’ certifications dated July 30, 1976 from both universities indicated that Lacson was not enrolled or graduated from those institutions. Lacson filed an answer on March 31, 1977 denying that the sheets were used to seek promotion or retention, and arguing that the elements of falsification (including intent to injure and duty to disclose) were not present.
On May 31, 1978 the Court referred the complaint to Acting Executive District Judge Zain B. Angas, Court of First Instance of Lanao del Sur, Marawi City, for investigation, report and recommendation. After hearings, Judge Angas found that Lacson had filed information sheets dated May 23, 1975 and August 19, 1975 with the Supreme Court records and that those sheets had accompanied a recommendation for Lacson’s promotion to Deputy Clerk of Court/Clerk III in Branch V, Iligan City. The Investigating Judge concluded that the information sheets contained untruthful statements about Lacson’s schooling, that the university certificates supported the charge, and that the misrepresentations showed a deliberate purpose to deceive rather than a mere clerical inaccuracy; he recommended a fine equivalent to three months’ salary as penalty.
The Supreme Court reviewed the Investigating Judge’s report and the documentary evidence, found the misrepresentations established and repeated over...(Subscriber-Only)
Issues:
- Did respondent Mariano Lacson commit acts of dishonesty by misrepresenting his educational attainments in his information/personal data sheets?
- If guilty, what is the appropriate administrative penalty for such misconduct by a ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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