Case Summary (G.R. No. 189609)
Allegations and Investigative Findings
On May 25, 1993, Atty. Cana reported the alleged falsification of an Order dated September 25, 1992, which directed the reconstitution of Title Certificate No. T-250603. The Order was presented to him by Enrico Fombo, who obtained it from Gerardo Flores, the attorney-in-fact for petitioner Alfredo de Guzman. Further investigation revealed that such an Order or Entry of Judgment had not been issued by Judge Montesa, Jr. Subsequent inquiries unveiled two additional spurious Orders dated February 15, 1993, linked to other petitions processed through Flores.
Referral for Investigation
Upon receiving the report, Executive Judge Natividad Dizon referred the matter to Vice-Executive Judge Demetrio B. Macapagal and the Criminal Investigation Service of the Philippine National Police for investigation. The investigation confirmed the existence of spurious Orders, leading to the filing of three counts of falsification of public documents against Belen Santos and a recommendation for administrative action.
Proceedings and Responses
Respondent Santos filed an unsigned and unverified Comment denying all falsification charges. An investigation hearing was held on April 19, 1994, followed by the submission of affidavits from both parties. Santos claimed ignorance regarding the authenticity of the Orders and denied any involvement in their issuance, stating no knowledge about them being spurious.
Executive Judge's Findings
Executive Judge Dizon's report highlighted the dubious nature of the Orders and Santos's proximity to the issuance of these documents. It was noted that while direct evidence of her authorship was lacking, her actions in processing the petitions for financial gain were prejudicial to the interests of public service. Dizon's recommendations underscored that her participation in the matter constituted a serious breach of her duties as a public servant.
Financial Transactions and Ethical Violations
Santos's arrangement to receive compensation for processing the reconstitution petitions raised serious ethical concerns. Although she was not an employee of the court branch where the petitions were filed, she engaged in dealings with Flores for monetary consideration, which contravened the prohibit
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Case Background
- This administrative case originated from a letter-report dated May 25, 1993, by Atty. Artemio D. Cana, the then Acting Register of Deeds of Bulacan.
- The report detailed allegations of falsification concerning an Order dated September 25, 1992, which was purportedly issued by Judge Camilo D. Montesa, Jr. of the Malolos Regional Trial Court (RTC), Branch 19.
- The alleged Order was related to a petition for the reconstitution of Transfer Certificate of Title (TCT) No. T-250603 filed by Alfredo de Guzman.
Allegations of Falsification
- The spurious Order directed the Register of Deeds to reconstitute the original copy of TCT No. T-250603 in the name of the petitioner and to issue the corresponding owner's duplicate copy.
- Inquiry revealed that the document was presented to Atty. Cana by Enrico Fombo, who was represented by Gerardo Flores, the attorney-in-fact for de Guzman.
- Further investigation indicated that no such Order or Entry of Judgment had been issued by Judge Montesa, Jr.
Discovery of Additional Spurious Orders
- On July 6, 1993, Clerk of Court Sinfronio Barranco transmitted two more spurious Orders dated February 15, 1993, which were also falsely attributed to Judge Montesa, Jr.
- These Orders were linked to other petitions for reconstitution of title filed by petitioners Angel Vasallo, Aurelia Jose, and Rosalina Gabriel, all represented by Gerardo Flores.
Investigation and Charges
- Upon r