A.M. No. 02-8-23-0 - Re: Fake Decision Allegedly in G.R. No. 75242

Dario G. Silvestre, Senior Manager, Credit and Appraisal Management of DBP, submitted to the Court photocopies of what was purported to be a certified true copy of a two‐page decision and a Resolution allegedly issued by the Second Division of the Supreme Court.
The decision, labeled under G.R. No. L‑75242 and titled “University of the Philippines, et al. v. Saint Mary Crusade to Alleviate Poverty of Brethren Foundation, Inc.,” appeared to have been promulgated on May 19, 2000, while the accompanying Resolution was dated March 2, 2000.
Multiple accompanying documents were presented, including a letter purportedly issued by the Clerk of Court, a Notice of Resolution, and a Certification dated August 14, 2000, all intended to support the authenticity of the case record.

The layout and signature format differed from authentic Supreme Court resolutions.
The number and names of the Justices listed exceeded the composition norm for a Division.
Terminological and stylistic errors (such as the improper indication of the ponente’s name) were prevalent.

The docket number G.R. No. 75242 was found to belong to a different case (Manila Resource Development Corporation v. National Labor Relations Commission and Ruben Manahan) promulgated in 1992, further casting doubts on the authenticity of the documents.

In June 2002, Ms. Teodora N. Villanueva presented herself at the DBP offices with these documents while seeking financing for a housing project allegedly undertaken by the Saint Mary Crusade to Alleviate Poverty of Brethren Foundation, Inc.
Mr. Silvestre personally conducted verification at the Court’s Office of the Clerk and discovered that:

The documents were mere photocopies lacking the required certification marks.
Signatures, initials, and the overall format did not conform with the actual issuance protocols of the Supreme Court.

In compliance with its internal directives, the Court ordered the National Bureau of Investigation (NBI) to discreetly investigate the matter and further required DBP Manager Silvestre to provide details concerning the source of the documents.

The NBI, through its agents and subsequent progress reports, noted the absence of a proper chain of evidence regarding the verification process, particularly the inability to identify the court personnel who assisted in the verification.
Multiple subpoenas were issued to key individuals (including Silvestre and certain officers of the involved organization), although responses and cooperation were mixed.
Internal communications within the Court revealed confusion regarding the issuance of negative certifications; the Office of the Clerk of Court stated that its practice was to certify only positive records (i.e., that a decision was actually issued), thus complicating the investigation.

The Court, recognizing that the alleged documents were blatantly falsified, emphasized that such acts harm the integrity of the judicial process.
Resolutions were passed directing:

Various officials (including the Administrator of the Land Titles and Deeds Registration Office, the Clerk of Court of the Second Division, the Chief of the Judicial Records Office, and the Chief Reporter) to issue certifications regarding the authenticity of documents under G.R. No. L‑75242.
The Clerk of Court en banc to execute an affidavit clarifying if she had issued related communications and certifications.

The investigation had to be reopened pending the production of the required certifications and the identification of the court employee involved in the earlier document verification.

The incident raised significant concerns regarding possible collusion between private parties and court personnel in fabricating judicial documents for financial gain.
The alleged use of falsified documents was seen as an assault on public faith, as such documents could mislead lenders and other institutions into financing projects on spurious grounds.
The matter underscored the critical need to safeguard the integrity of judicial records and to ensure strict accountability in the issuance and certification of court documents.

Whether the photocopied decision and resolution purportedly issued by the Second Division of the Supreme Court were in fact genuine or fabrications.
Determining the veracity of accompanying documents (e.g., the Notice of Resolution, the Letter, and the Certification) that were meant to corroborate the authenticity of the supposed court decision.

Whether the falsification and simulation of a decision and resolution compromise the integrity and public faith in the Court’s processes and decisions.
The extent of the damage inflicted upon the judicial system by the circulation of spurious documents.

The necessity of identifying the court personnel who assisted in verifying the documents submitted by DBP Manager Silvestre.
Whether the failure to obtain negative certifications (stating that no such decision was issued) impeded efforts to conclusively demonstrate the falsification of public documents.

Whether individuals such as Teodora Villanueva, Jaime Borjal, Felicisimo Arellano, and possibly colluding court staff should be held criminally liable for the creation, use, and distribution of forged documents.
The proper role and responsibilities of the Clerk of Court and other administrative officials in ensuring the authenticity of judicial communications.