Title
Agloro vs. Burgos
Case
A.M. No. P-16-3550
Decision Date
Jan 31, 2017
Irregularities in handling a title reconstitution case led to administrative charges; two court personnel dismissed for grave misconduct and dishonesty.

Case Summary (A.M. No. P-16-3550)

Antecedents

On May 17, 2012, Judge Agloro reported irregularities regarding the LRC case to then-Executive Judge Renato C. Francisco through a Private and Confidential Memo. He indicated that the case was improperly recorded in Branch 83 instead of the correctly designated Branch 77, where it was originally raffled. Judge Agloro noted the complications that arose from this error, particularly the pending motion for execution amidst unresolved legal queries. Following this report, the incoming Executive Judge Ma. Theresa V. Mendoza-Arcega conducted a wider investigation into the matter, prompting further inquiries to clarify the raffle process and case handling discrepancies.

Investigation Report of Executive Judge Mendoza-Arcega

Executive Judge Mendoza-Arcega's investigation corroborated Judge Agloro's findings, confirming that the LRC case was indeed improperly assigned to Branch 83. Notably, it uncovered forged signatures in the documentation related to the case’s entries in Branch 83. The investigation included testimonies from judges and court personnel, revealing multiple lapses and anomalies that involved several personnel from both branches of the Regional Trial Court, including contradictory narratives about the handling of case files and entries.

Respondents' Positions and Responses

Each respondent provided their accounts during the inquiry. Burgos, the OIC, asserted her lack of involvement in the corruption and attributed the misconduct to Santiago and Garcia. Fajardo indicated her accidental discovery of the misassignment of the LRC case, while both Santiago and Garcia reiterated their defenses without addressing key points raised against them. Garcia, in particular, claimed limited involvement and framed her actions as procedural assistance rather than part of any misconduct.

OCA's Recommendation

On July 28, 2016, the Office of the Court Administrator (OCA) submitted a recommendation that resulted in varied outcomes for the respondents. The recommendation proposed the dismissal of Burgos and Fajardo due to the lack of solid evidence against them. Conversely, it found Santiago guilty of Simple Neglect of Duty and recommended a reprimand, while Garcia was held accountable for serious ethical violations, leading to her dismissal from government service.

The Court's Ruling

The Court upheld the findings of the OCA regarding Burgos, who effectively assisted in uncovering the misconduct rather than participating in it. The charges against Fajardo were dismissed based on insufficient evidence despite her involvement in reporting the discrepancies. However, the Court modified the ruling against Santiago, determining that her acti

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