Title
Office of the Court Administrator vs. Del Rosario
Case
A.M. No. MTJ-94-949
Decision Date
Dec 13, 1994
Atty. del Rosario, former Clerk of Court, found guilty of gross negligence for failing to account for a missing official receipt and irregularities in financial reporting, fined P5,000.

Case Summary (A.M. No. MTJ-94-949)

Background of the Case

The proceedings stem from a letter dated June 10, 1992, from Mr. Ramon O. de Vera, a State Auditor, referring to an earlier communication from Mr. Jose C. Cabarles, a Provincial Auditor regarding the cash and accounts examination of respondent Deogracias K. del Rosario. The examination revealed one missing official receipt (General Form 13-A, SN 9797272), which the respondent, as the accountable officer, was required to account for. Further discrepancies were noted, including untimely reporting of collections and unsatisfactory documentation.

Internal Memorandums and Directives

Following the audit report, several memorandums were issued by the OCA, urging respondent Del Rosario to resolve the accountability issues before assuming his judicial role. These directives included requests for explanations regarding missing documentation and warnings of potential administrative charges for non-compliance. Despite these repeated requests, Del Rosario failed to provide satisfactory responses or documentation.

Formal Charges and Findings

Ultimately, the OCA filed formal charges against Del Rosario, citing grave misconduct and negligence due to his failure to account for the missing receipt, non-compliance with records submission requirements, and possible fraudulent implications stemming from the lack of prompt reporting as mandated by the Commission on Audit (COA) circulars. The charges encapsulated his overall failure to maintain the standards expected of an accountable officer.

Del Rosario's Defense

In response to the charges, Del Rosario contended his defense based on a belief that attending a seminar for judges sufficed for resolving his accountabilities. He also cited office inefficiencies, a lack of formal turn-over documents when he assumed his position, and attempted to justify the missing receipt by referencing past incidents of office burglary and his prior positive audit history.

Administrative Recommendations and Court Analysis

The Office of the Court Administrator recommended sanctions against Del Rosario, underscoring the need for accountability amidst gross negligence illustrated by ignoring multiple official communications. Despite acknowledging the absence of damages incurred due to the missing receipt, the OCA

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