Title
Supreme Court
IN RE: Incorrect entries in the daily time record of Lorna M. Martin, court stenographer I, Municipal Circuit Trial Court, Tarlac
Case
A.M. No. 15-05-50-MCTC
Decision Date
Feb 28, 2024
Court stenographer Lorna M. Martin found guilty of serious dishonesty, gross misconduct, and gross insubordination for falsifying DTRs and logbook entries, defying superiors, and prior offenses, resulting in fines totaling PHP 310,000.

Case Summary (A.M. No. 15-05-50-MCTC)

Allegations and Initial Complaints

In a letter dated September 3, 2014, Judge Gandia-Asuncion alleged that Martin had submitted incorrect entries in her DTR, specifically claiming she was present in the office on certain dates when she was not. Notably, on August 11, 2014, Martin recorded a work schedule that was later disputed, leading Judge Gandia-Asuncion to sign her DTR "with reservation." The same concern arose for May 6, 2014, and additional discrepancies were noted for May 16, 2014.

Martin’s Response

In response to the allegations, Martin submitted her Comment on September 16, 2015, denying any wrongdoing and asserting that she had in fact reported for work on the dates in question. She claimed mistakes in her DTR were due to oversight and admitted to refusing an order from Judge Gandia-Asuncion to explain her entries due to feeling unwell. Martin insisted that negative motivations from colleagues and the judge influenced the accusations against her.

Investigation and Findings

The Court referred the matter to Judge Rixon M. Garong for investigation under a Resolution dated April 18, 2018. Judge Garong directed the complainants to respond to Martin's comments and collected sworn statements. After reviewing the evidence, including logbook discrepancies, Judge Garong concluded that Martin was guilty of tampering with her DTR on multiple occasions, exhibiting insubordination towards her superiors, and failing to adhere to office regulations.

Recommendations and Further Resolutions

The Office of the Court Administrator (OCA) issued a recommendation on December 7, 2018, declaring Martin guilty of dishonesty and insubordination, proposing a two-month suspension without pay along with a stern warning regarding future infractions. The OCA's findings supported the allegations of dishonesty based on Martin's repeated falsification of her attendance records.

Court’s Conclusion on Guilt and Penalties

Upon review, the Court upheld the factual conclusions drawn by the OCA but modified the penalty. It emphasized the gravity of falsifying attendance records as a serious offense that undermines public trust. The Court ultimately determined that Martin's actions constituted serious dishonesty and gross misconduct due to her repeated failure to accurately record her attendance and refusal to comply with lawful orders.

Penalty Assessment

The Court applied penalties per Rule 140 of the Rules of Court and took into account Martin's prior conduct.

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