A.M. No. P-11-2989, January 10, 2017
Wyna Marie P. Garingan-Ferreras, Complainant, vs. Eduardo T. Umblas, Legal Researcher II, Regional Trial Court, Branch 33, Ballesteros, Cagayan, Respondent.

FACTS

Complainant Wyna Marie G. Ferreras received in 2009 a copy of a Certificate of Finality dated March 24, 2006, bearing the signature of respondent Eduardo T. Umblas as Officer-in-Charge Clerk of Court. The certificate pertained to a Civil Case for Declaration of Nullity of her marriage, which she had no knowledge of. An annotation on her marriage record at the National Statistics Office confirmed the nullity decree. However, upon her request, the RTC of Ballesteros, Cagayan, issued a certification stating that no such case file existed.
In his Comment, respondent denied the allegations, claiming the documents were fraudulent and his signatures were spurious. He also asserted he was no longer the OIC Clerk of Court at the time of the certificate’s issuance. The case was referred for investigation. The Investigating Judge noted that complainant attended all hearings, while respondent did not appear despite notice. The evaluation centered on documentary evidence, particularly the signature on the Certificate of Finality.

ISSUE

Whether respondent Eduardo T. Umblas is administratively liable for falsification of a public document and dishonesty.

RULING

Yes, the Court found respondent guilty of falsification of a public document and dishonesty. The legal logic rests on the principle that substantial evidence suffices in administrative proceedings. The Investigating Judge and the Office of the Court Administrator both concluded that the signature on the spurious Certificate of Finality bore a striking resemblance to respondent’s authentic signature in his filed Comment. Respondent’s mere denial of participation and claim of forgery were deemed insufficient, as he failed to present clear and convincing evidence to substantiate his defense. The act of falsifying an official court document constitutes grave misconduct and a severe breach of the trust and integrity required of all judiciary personnel.
However, the Court noted that in a separate recent administrative case, respondent had already been dismissed from service for a similar offense of producing spurious court documents. Since the penalty of dismissal was no longer feasible, the Court imposed a fine of Forty Thousand Pesos (₱40,000.00) to be deducted from his accrued leave credits. The OCA was also directed to file the appropriate criminal charge against him.