Case Digest (A.M. No. P-15-3342)
Facts:
Judge Tomas D. Lasam v. Ronald L. Mamauag, A.M. No. P-15-3342 (Formerly OCA IPI No. 09-3074-P), July 30, 2024, the Supreme Court En Banc, Per Curiam. Complainant is Judge Tomas D. Lasam, then Presiding Judge of the Municipal Trial Court (MTC), Rizal, Cagayan; respondent is Ronald L. Mamauag, Clerk of Court II of the same court.The administrative matter arose when Mamauag failed to timely submit his daily time records (DTRs) for February to October 2008, causing his salaries and benefits for those months to be withheld. Mamauag later submitted DTRs for that period to the Office of the Court Administrator (OCA) but without Judge Lasam’s certification. Deputy Court Administrator Reuben P. Dela Cruz referred the DTRs to Judge Lasam for signature. In a letter dated December 11, 2008, Judge Lasam refused to certify the DTRs, citing numerous discrepancies between the MTC logbook and the submitted DTRs (mismatching time-in/time-out entries; entries present in one record but not the other), and stating that the logbook entries for February–October 2008 did not appear to be in Mamauag’s handwriting or bear his usual initials/signature.
The OCA treated Judge Lasam’s letter as a complaint and required Mamauag to file a Comment. Mamauag denied intent to falsify, asserted a mistaken belief he should submit a Certificate of Service rather than a DTR under the 2002 Revised Manual for Clerks of Court, and claimed his handwriting had changed due to strokes; he submitted a municipal resolution attesting to his punctuality and affidavits in support. Judge Lasam filed a Reply maintaining that Mamauag failed to refute specific charges and that a “human miscalculation” defense could set a dangerous precedent.
The Court En Banc referred the case to the Executive Judge of the Regional Trial Court of Tuao, Cagayan for investigation. Judge Rolando R. Velasco began the inquiry but retired; the investigation was continued by Judge Edmar P. Castillo, Sr., who, after receiving testimony (including from MTC Interpreter Jesus Mamba and Court Stenographer Priscilla Mangiduyos) and comparing exhibited signatures and entries, concluded in an Investigation Report/Recommendation (Aug. 27, 2014) that the contested logbook entries were not in Mamauag’s handwriting and recommended dismissal for dishonesty.
The Supreme Court re-docketed the complaint as a regular administrative matter (Resolution dated July 15, 2015), invited the parties to indicate whether the case could be resolved on the records, and later, upon the Judicial Integrity Board’s (JIB) recommendation (after noting Mamauag did not file a compliance), allowed the JIB to proceed to report based on the records. The JIB–Office of the Executive Director (OED) (Feb. 20, 2023) and the JIB Proper (Apr. 3, 2023) reviewed the evidence, concurred with the...(Pro-only)
Issues:
- Was respondent Ronald L. Mamauag administratively liable for serious dishonesty and falsification of public documents?
- If liable, is dismissal from service with forfeiture of benefits (excluding accrued leave) and disqualification from public office the ap...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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