A.M. No. P-1551 - Benaojan vs. Lacson

Case Summary (A.M. No. P-1551)

Factual Background

Petitioner’s sworn letter-complaint asserted that respondent falsified his personal data sheets with deliberate intent to gain promotional appointments in the government service. The alleged falsity related to the section on college and university education, where respondent purportedly represented that he completed Associate in Arts (Pre-Law) at the University of the East (1950-1952), pursued law at the University of Manila for specified periods, and completed additional law and training-related entries, including Customs Administration.

Petitioner further alleged that respondent had never studied law in either institution. Petitioner supported this claim with certifications from the registrars of the University of the East and the University of Manila, both dated July 30, 1976, which stated that respondent was not enrolled or did not graduate as claimed in the personal data sheets.

Respondent, in his answer dated March 31, 1977, denied criminal intent and disputed the factual premise of dishonesty. He claimed that the questioned personal data sheets were never used by him to obtain promotion or to secure retention in the service. He also argued that, for falsification under Articles 171(4) and 172(1) of the Revised Penal Code, intent to injure and an obligation to disclose were essential elements, and that no injury—much less to petitioner—had occurred.

Referral and Investigating Judge’s Findings

On May 31, 1978, the case was referred to Acting Executive District Judge Zain B. Angas of the Court of First Instance of Lanao del Sur, Marawi City for investigation, report, and recommendation. After hearings, the investigating judge submitted a report that the Court quoted substantially.

The investigating judge found that respondent was a Clerk in the Court of First Instance, Branch I, Marawi City, and was then detailed to the Court of First Instance at Iligan City. The report emphasized that respondent was recommended as Deputy Clerk of Court, Court of First Instance, Branch IV, Iligan City, and that, to support the recommendation, he attached his information sheet dated August 19, 1975. The report stated that respondent also complied with a Memorandum Circular issued by Chief Justice Querube Makalintal dated April 29, 1975, which required court personnel to accomplish their Information Sheet and Service Record Form to update their personal files for the Supreme Court. Pursuant to that circular, respondent accomplished and filed his information sheet and service record form dated May 23, 1975.

In both information sheets, respondent allegedly represented that he was a graduate in Associate in Arts (Pre-Law) of the University of the East in 1952 and a graduate of law of the University of Manila in 1967. The investigating judge noted that petitioner had obtained copies of these documents from the Supreme Court through a letter-request dated July 28, 1976. The report relied on documentary evidence showing that the University of Manila had no record of respondent being enrolled or graduating from its College of Law as claimed, and that the records of the University of the East failed to show respondent was enrolled in that institution.

Respondent’s defense, as characterized in the report, was that the August 19, 1975 information sheet was made and filed without any specific purpose and was not intended to seek promotional appointments. The investigating judge rejected this position by pointing to respondent’s own annex and to the evidence showing that the information sheet accompanied the recommendation for the deputy clerk position and served to demonstrate qualifications. The report also found respondent’s claim that the May 23, 1975 information sheet was merely for updating personal files to be insufficient where the misrepresentations themselves remained uncontradicted.

The investigating judge concluded that respondent made untruthful statements in his information sheets and that the misrepresentation as to educational attainment constituted dishonesty warranting disciplinary action. Considering respondent’s years of judicial service, the investigating judge recommended a fine equivalent to three (3) months salary as Clerk.

Court’s Assessment of Respondent’s Defenses and Evidence

In reviewing the report and the parties’ submissions, the Court found a “dismal failure” on respondent’s part to contradict the concrete evidence of the charge, particularly the untruthful statements and misrepresentations in his personal data sheets. The Court held that respondent’s assertion that the personal data sheets had not been used to seek promotion or to secure retention amounted to an admission of misrepresentation.

The Court further explained that any qualifications respondent labeled in his information sheet would have influenced the determination of retention and promotion in the service. The Court also treated as decisive the investigating judge’s finding that respondent’s information sheet was used to accompany the recommendation for promotion to Deputy Clerk of Court and/or Clerk III in the Court of First Instance, Branch V. This factual finding, as adopted by the Court, effectively defeated respondent’s claim that the information sheets were filed for no specific purpose.

The Court also focused on the repeated nature of respondent’s misrepresentations. It found that respondent repeated the same type of dishonesty and misrepresentation regarding schooling in different universities and at different times spanning the period from 1950 to 1967, including claims that he finished Pre-Law, 4th year Law, and 1st year in Customs Administration. The Court characterized this as indicating a decided purpose to deceive and mislead superior officers, rather than a mere routine or technical act.

The Parties’ Contentions

Petitioner maintained that respondent falsified personal data sheets by misrepresenting educational attainment, relying on the certifications issued by registrars indicating that respondent did not study or graduate as stated. Petitioner’s narrative framed the conduct as a deliberate attempt to gain promotional appointments in the government service.

Respondent argued that the elements required for falsification of public documents under Articles 171(4) and 172(1) of the Revised Penal Code were not present, stressing that intent to injure third persons and an obligation to disclose facts were necessary, and that no injury had been caused to petitioner. He also insisted that the sheets were not used for promotion or retention, and that his filing was mainly compliance with the memorandum circular updating his 201 files.

Legal Basis and Reasoning

Although the complaint invoked the criminal provisions on falsification, the Court treated the decisive inquiry as whether respondent committed dishonesty and betrayed public trust through untruthful statements in official documents submitted in the judicial service. The Court accepted the investigating judge’s evidentiary assessment that respondent’s educational claims were unsupported by school records and that the misrepresentations were knowingly and repeatedly stated in official information sheets.

The Court then anchored its disciplinary ruling on constitutional principles relating to the accountability of public officers and the character of public office as a public trust. It invoked the constitutional provision on Accountability of Public Officers, emphasizing that public officers must serve with the highest degree of responsibility, integrity, loyalty, and efficiency, and remain accountable to the people. The Court stressed that the Constitution demanded superlative integrity and that treating betrayal of the public trust lightly would contravene official duty to uphold constitutional mandates. It reasoned

Case Syllabus (A.M. No. P-1551)

Juanito Benaojan filed a sworn letter-complaint as Interpreter and Special Deputy, Court of First Instance of Lanao del Norte, Iligan City, against Mariano Lacson, a Clerk, Court of First Instance of Lanao del Sur, Branch I, Marawi City, for falsification in personal data sheets.
The complaint alleged that respondent submitted false personal information in two separate information sheets: one subscribed before Asst. Provincial Fiscal Benedicto A. Lagrosa on May 23, 1974, and another subscribed before Executive District Judge Moises Dalisay, Sr. on August 19, 1975.
The falsity concerned respondent’s claimed educational background, specifically his supposed studies in the University of the East and the University of Manila.
Complainant alleged that respondent was only a high school graduate and had never studied law in those institutions, as shown by certifications issued by the respective registrars dated July 30, 1976.
Respondent answered and denied criminal falsification theories by asserting that the personal data sheets were not used for promotion or for retention and that no injury occurred to complainant.
Respondent further argued that, under the theory of falsification of public documents under Articles 171(4) and 172(1) of the Revised Penal Code, intent to injure and an obligation to disclose facts were required elements, and that those were absent.

Referral and Investigation Process

On May 31, 1978, the case was referred to Acting Executive District Judge Hon. Zain B. Angas of the Court of First Instance of Lanao del Sur, Marawi City for investigation, report, and recommendation.
Judge Angas conducted hearings and evaluated both documentary and testimonial evidence submitted by the parties.
The Investigating Judge submitted a report and recommendation to the Court, concluding that respondent made untruthful statements and misrepresentations in the information sheets.

Key Factual Allegations

Complainant alleged that respondent falsified educational attainments by narrating in the personal data sheets that he was an Associate in Arts (Pre-law) graduate of the University of the East during 1950 to 1952, and a law graduate of the University of Manila during 1967, among other entries.
Complainant alleged that respondent also represented multiple educational periods and law-related schooling that purportedly took place at different times and institutions.
Respondent’s falsified information sheets were treated as official personal records affecting his service status.
Complainant alleged that he obtained xerox copies from the Supreme Court through a letter-request dated July 28, 1976, and then relied on registrar certifications dated July 30, 1976 to prove the falsehood.
The Investigating Judge found that the respondent’s claim of schooling was not supported by institutional records as presented in the case.

Administrative Evidence Considered

The Investigating Judge established that respondent served as a Clerk in CFI Branch I, Marawi City, and was detailed to CFI at Iligan City.
The Investigating Judge found that respondent had been recommended for the position of Deputy Clerk of Court, CFI, Branch IV, and that, to support that recommendation, he attached an information sheet dated August 19, 1975.
The Investigating Judge found that, in compliance with a memorandum circular issued by Chief Justice Querube Makalintal dated April 29, 1975, respondent accomplished and filed an Information Sheet and Service Record Form dated May 23, 1975 with the Supreme Court.
The Investigating Judge reported that in both information sheets respondent represented being a University of the East (Pre-law) graduate and a University of Manila law graduate, and those sheets were in the Supreme Court records.
The Investigating Judge noted evidence that the University of Manila had no entry showing the respondent enrolled or graduated from the College of Law.
The Investigating Judge also noted evidence that records of the University of the East failed to show respondent’s enrollment in that institution.
The Investigating Judge found that respondent did not substantiate the factual claims contained in the information sheets.

Respondent’s Defenses

Respondent denied that the questioned personal data sheets were us