Case Summary (A.M. No. P-292)

Administrative Charges Against Respondent

The respondent, Manuel Resultan, Sr., was administratively charged with two primary offenses: infidelity in the custody of public records and discourtesy, inefficiency, and incompetence in the performance of his official duties. These charges arose from the loss of records pertaining to Criminal Case No. CC-875. The investigation revealed that the respondent did not destroy the missing record for any illicit purpose, and there was no evidence of malice or evil intent associated with the loss. Furthermore, the record was reconstituted promptly after the loss was reported, and the parties involved in the criminal case did not suffer any prejudice as a result.

• Charges: Infidelity in custody of public records; discourtesy, inefficiency, incompetence.
• Investigation Findings: No illicit purpose in record loss; no malice; prompt reconstitution of records; no prejudice to parties involved.

Investigation and Findings

During the investigation, it was noted that the respondent made diligent efforts to locate the missing records but was unsuccessful. The case was eventually tried, and the accused was convicted without any complaints from the parties involved. The Inquest Judge concluded that the respondent acted in good faith and that the loss of the records did not result in any damage to the complainant or the accused. The absence of evidence indicating any wrongdoing on the part of the respondent led to the recommendation for dismissal of the complaint.

• Efforts to Locate Records: Diligent but unsuccessful.
• Trial Outcome: Accused convicted; no complaints from parties.
• Inquest Judge's Conclusion: Good faith actions; no damage caused; recommendation for dismissal.

Recommendations and Supreme Court's Decision

The Office of the Court Administrator supported the Inquest Judge's findings and recommended that the respondent be exonerated but also advised that he should be more vigilant in his duties. The Supreme Court agreed with these recommendations, dismissing the administrative complaint while admonishing the respondent to exercise greater care in the custody of official documents. The Court warned that any future similar acts or omissions would be dealt with more severely.

• Office of the Court Administrator's Recommendation: Exoneration with admonition for vigilance.
• Supreme Court's Action: Dismissal of complaint; admonishment for greater care; warning of severe consequences for future infractions.

Conclusion and Implications for Respondent

The Supreme Court's decision underscores the importance of diligence and care in the management of publi...continue reading

Case Syllabus (A.M. No. P-292)

Case Overview

• Atty. Isidro G. Arenas filed a formal complaint against Manuel Resultan, Sr., the Clerk of Court of the City Court of San Carlos City.
• The complaint comprised two primary charges:
  • Infidelity in the custody of public records
  • Discourtesy, inefficiency, incompetence in the performance of official duties, and conduct prejudicial to the best interest of the service.

Allegations Against Respondent

• Infidelity in Public Records:

  • Atty. Arenas alleged that Resultan failed to locate the records for Criminal Case No. CC-875, which involved the People of the Philippines vs. Rodrigo de Guzman, despite repeated inquiries.
  • This became particularly pressing when Arenas needed to verify the regularity of a bail bond posted by the accused.

• Discourtesy and Inefficiency:

  • Arenas claimed that when he attempted to verify the records to file the bail bond, Resultan responded with an arrogant attitude, showing disrespect and neglecting his inquiries.

Respondent's Defense

• Resultan presented a defense citing an incident on July 3, 1974, where he was approached by individuals including Arenas regarding bail ...continue reading