G.R. No. L-49395 - Green Valley Poultry and Allied Products, Inc. vs. Intermediate Appellate Court

The case arose from a memorandum dated May 29, 2017, submitted by the Office of the Court Administrator (OCA).
The OCA based its action on an Audit Team’s Report dated May 9, 2017, which was connected to A.M. No. RTJ-15-2404.
The report recommended that Branch Clerk of Court Paulino I. Saguyod explain why he should not be held administratively liable.

The Audit Team examined 1,194 cases handled by former Judge Liberty O. CastaAeda of the Regional Trial Court (RTC), where BCC Saguyod was also stationed.
They found discrepancies not only in the judge’s handling of the cases but also in Saguyod’s conduct in notarizing various documents.
It was discovered that Saguyod notarized documents filed before the RTC without observing the requisite guidelines outlined in Section (f) of the Resolution dated August 15, 2006, in A.M. No. 02-8-13-SC.
Specifically, Saguyod failed to certify that there were no available notaries public in the Municipality of Paniqui, Tarlac as required.

In his Explanation dated July 31, 2017, BCC Saguyod claimed that he notarized the documents in good faith and without any monetary consideration.
He cited Section 41, Chapter 10, Book I of the Administrative Code of 1987, arguing that clerks of courts are authorized to administer oaths and perform such functions vital to the administration of justice.
Saguyod apologized for not strictly adhering to the provisions of the Rules on Notarial Practice and indicated that he ceased notarizing subsequent documents after being alerted by the Audit Team.

On December 14, 2017, the OCA, in its memorandum, recommended that Saguyod be found guilty of inefficiency and incompetence in the performance of official duties.
The recommendation included a penalty of suspension from service for one (1) year, along with a stern warning that repetition of the offense would lead to dismissal from service.
The OCA dismissed Saguyod’s defense regarding the absence of available notaries public by pointing out the existence of notaries public in Paniqui, Tarlac, and by noting that Saguyod notarized documents even when they were incomplete.

Whether BCC Saguyod should be held administratively liable for notarizing documents submitted to the RTC without strictly complying with the provisions of A.M. No. 02-8-13-SC.
Whether his defense—based on good faith, absence of monetary benefit, and the assertion of there being no available notaries public in Paniqui—is sufficient to absolve him from administrative liability.