Case Summary (A.M. No. P-92-1-029-RTC)
Factual Background
Former Judge Enrique T. Jocson approved three property bonds that subsequently were discovered to be supported by forged certifications. These bonds, submitted by his Legal Researcher Ramiro J. Mendoza on August 18, 1991, were filed for cases that had yet to be raffled for judicial assignments. The discrepancies came to light when Atty. Corazon T. Romero scrutinized the certifications, leading to further investigation confirming that multiple signatures on the documents were forged.
Response to Discrepancies
Upon confirming the forgeries, Judge Jocson took action by issuing warrants for the re-arrest of the accused involved in the cases. Furthermore, Executive Judge Ponferrada referred the matter to the Philippine National Police (PNP) for investigation. The PNP subsequently discovered potential criminal acts by Mendoza and Labansawan, leading to charges being filed against Labansawan for multiple counts of falsification but not against Mendoza, as the evidence was less compelling.
Administrative Proceedings
A detailed investigation was led by Vice-Executive Judge Katalbas-Moscardon. Mendoza defended himself by asserting his belief that the bonds were valid and that his involvement was in service to the judicial system, aimed at facilitating the accused's right to bail. The investigation revealed systemic issues of property bond submission and involved numerous testimonies, uncovering that Mendoza relied on previously accepted documents and assumed their legitimacy without further verification.
Findings of the Investigation
The investigation concluded that while Mendoza handled bonds that included forged documentation, there was insufficient evidence to establish intentional wrongdoing or collaboration between him and Labansawan. The insinuations of fraud were not substantiated sufficiently to charge Mendoza with criminal complicity. His responses during the investigation, albeit noted as evasive by the Investigating Judge, did not provide direct evidence of malicious intent.
Disciplinary Action
Despite being absolved of criminal charges, Mendoza was found negligent in his duties as a Legal Researcher, with a notable level of responsibility expected given his extensive experience in the court system. The Court noted that while ultimate accountability lay more significantly with Judge Jocson and his administrative duti
...continue readingCase Syllabus (A.M. No. P-92-1-029-RTC)
Case Background
- This case originated from the actions of former Judge Enrique T. Jocson of the Regional Trial Court, Branch 47, Bacolod City, regarding three property bonds with forged certifications.
- The bonds were submitted by Ramiro J. Mendoza, a Legal Researcher, on 18 August 1991, a Sunday, prior to the scheduled raffling of the criminal cases on 20 August 1991.
- Criminal Cases Nos. 10648, 10649, and 10650 involved accused individuals who posted bail using these property bonds.
- Atty. Corazon T. Romero, Clerk of Court, raised suspicions about the authenticity of the certifications on the bail bond, leading to an investigation.
Investigation and Findings
- Atty. Rolando Q. Navales, the Register of Deeds, denied signing the certifications, confirming the suspicion of forgery.
- Judge Jocson responded by issuing an alias warrant for one accused and recalling the release orders for the other two accused based on the forged bonds.
- Executive Judge Bernardo T. Ponferrada referred the matter to the Philippine National Police (PNP) for further investigation, which implicated Mendoza and Engr. Dominador Labansawan in the commission of falsification of public documents.
Legal Proceedings and Outcomes
- A resolution by the Tanodbayan Prosecutor found sufficient grounds to file charges against