A.M. No. P-02-1591. June 21, 2002.
Corazon B. Joson, complainant, vs. Stenographer III Ruth A. Macapagal and Stenographer III Teresita C. Burkley, respondents.

FACTS

Complainant Corazon B. Joson obtained a housing loan from the GSIS. Due to financial difficulties, she decided in 1996 to transfer her rights over the property to Noemi V. Alomia, sister of respondent Ruth Macapagal. Witnesses included Macapagal and co-respondent Teresita Burkley. Macapagal volunteered to have the documents notarized and submitted to GSIS. Joson, trusting Macapagal, delivered her copies. In 2000, Joson received a demand letter from GSIS. Upon inquiry, she discovered Macapagal never submitted the documents. Instead, the property had been sold to Carmelita Cabigas, sister of Burkley, with the original transferee’s name erased and replaced on the documents.
Respondents claimed the first buyer, Alomia, backed out. Macapagal then offered the property to Cabigas in 1997. They asserted Joson agreed to a new contract with Cabigas, provided the old documents were returned, and that the erasures and substitutions on the new deed were made with Joson’s knowledge. They denied forgery, presenting an affidavit from Cabigas. The documents for this second transaction were notarized only in 1999.

ISSUE

Whether respondents Macapagal and Burkley committed conduct unbecoming of court employees warranting administrative sanction.

RULING

Yes, respondents are administratively liable. The Court found their explanations implausible and their actions demonstrated dishonesty and impropriety. The sequence of events—Macapagal’s failure to submit the initial documents, the unexplained erasures and superimpositions on the second deed, the entrustment of the old documents to Burkley instead of returning them to Joson as promised, and the inordinate delay of over a year in notarizing the second set of documents—collectively indicate the second transfer was conducted without Joson’s full knowledge and consent. This course of action prejudiced Joson’s interests, exposing her to continued liability with GSIS.
The Court emphasized that every judiciary employee must uphold the highest standards of honesty and integrity in both official duties and private dealings to preserve the court’s integrity. Respondents’ actions fell short of this strict standard. While Cabigas’s later offer to assume the loan obligations may mitigate the penalty, it does not absolve respondents of their misconduct. Accordingly, the Court reprimanded and sternly warned respondents Ruth A. Macapagal and Teresita C. Burkley.