Case Summary (A.M. No. P-08-2549)
Facts of the Case
On March 6, 2007, the Office of the Court Administrator (OCA) received an anonymous complaint accusing Curamen of falsifying a public document related to the registration of a child's birth. The complainant alleged that Curamen registered the birth of a child, named Rica Mae Baldonado Curamen, claiming herself as the biological mother, when, in reality, she was the child's maternal grandmother. The complainant provided the original birth certificate, indicating that the child's true name was Rinea Mae Curamen Aquino, and that her parents were Olga Mae Baldonado Curamen Aquino and Jun Aquino. Further investigation by Executive Judge Rodrigo S. Caspillo confirmed that Curamen's daughter Olga was, in fact, the true mother of the child.
Respondent's Admission and Justifications
In her comment, Curamen acknowledged that the real parents of the child were Olga and Jun Aquino. She claimed that these parents were unemployed and dependent on her for support. Curamen asserted that the decision to register the child's birth under her name was made with her daughter’s consent, alleging a common Filipino practice of extending assistance to family members. She denied any attempt to falsify her income tax return, claiming that she did not list the child as an additional dependent.
OCA’s Report and Recommendation
The OCA’s Report found Curamen guilty of conduct prejudicial to the best interest of the service due to her actions, which could negatively affect public perception regarding the integrity of court officials. However, the OCA did not find sufficient evidence to conclude that Curamen had falsified her income tax return. They recommended a suspension of six months and one day from her service as a consequence of her actions.
Court’s Ruling on Income Tax Return
Upon review, the court concurred with the OCA's findings regarding the income tax return, noting that there was no evidence of Curamen claiming the child as an additional dependent. The burden of proof lies with the complainant, who failed to present convincing evidence in support of their allegations.
Court’s Ruling on Falsification of the Birth Certificate
The court, however, found Curamen guilty of dishonesty and falsification of a public document concerning the birth certificate. It emphasized that a birth certificate is a public document that, when falsified, undermines public faith and the truth that such documents are meant to represent. The court rejected her defense, stating that such concealment of the child’s true lineage did not serve the intended purpose of support but instead constituted a breach of legal and ethical standards expected from a court o
...continue readingCase Syllabus (A.M. No. P-08-2549)
The Case
- This administrative case involves Emma Baldonado Curamen, who serves as Court Interpreter I at the Municipal Trial Court of Rizal, Nueva Ecija.
- The case centers on allegations of dishonesty and falsification of a public document.
The Facts
- On March 6, 2007, the Office of the Court Administrator (OCA) received an anonymous complaint against respondent Curamen.
- The complaint accused Curamen of falsifying a public document and simulating the birth of a child named Rica Mae Baldonado Curamen in the local civil registry.
- It was alleged that Curamen misrepresented herself as the biological mother of Rica Mae, while in fact, she was the child's maternal grandmother.
- The complainant provided the original birth certificate, which identified the child's real name as Rinea Mae Curamen Aquino, with her parents being Olga Mae Baldonado Curamen Aquino and Jun Aquino.
- The report from Executive Judge Rodrigo S. Caspillo confirmed that Rica Mae Baldonado Curamen and Rinea Mae Curamen Aquino were indeed the same child and verified that Olga was Curamen's daughter.
- The original birth of Rinea was registered under Registry No. 2005-15495 in Cabanatuan City.
- Curamen executed an affidavit for delayed registration on March 31, 2006,