AM P 01 1507; (August, 2003) (Digest)
A.M. No. P-01-1507; August 28, 2003
Office of the Court Administrator vs. Rolando Saa
FACTS
Respondent Rolando Saa, Clerk of Court of the Municipal Circuit Trial Court (MCTC) of Camarines Norte, filed an administrative complaint (A.M. No. 97-336-P) against several employees of the Metropolitan Trial Court (MeTC) of Quezon City, Branch 42. He alleged that he traveled from Camarines Norte to Quezon City on June 5 and 6, 1997, to attend hearings in a civil case where he was a defendant, only to find the hearings cancelled without timely notice. He accused the employees of dishonesty and neglect for the belated mailing of the notice of postponement.
During its investigation of Saa’s complaint, the Office of the Court Administrator (OCA) recommended dismissing the charges against the MeTC employees, finding the delay was due to a utility worker’s negligence. However, the OCA discovered a discrepancy: while Saa claimed in his complaint to have been in Quezon City on June 5 and 6, 1997, his certified Daily Time Record (DTR) for June 1997 indicated he was present for work at his home court in Camarines Norte on those same dates.
ISSUE
Whether respondent Rolando Saa is administratively liable for falsifying his Daily Time Record.
RULING
Yes, respondent Saa is administratively liable. The Court found his explanation for the discrepancy unsatisfactory and indicative of dishonesty. Saa claimed he inadvertently recorded his vacation leave on June 25 instead of June 5, 1997, attributing this to lapses in memory, volume of work, and age. The Court, agreeing with the OCA, rejected this. The explanation failed to account for the second day of absence, June 6, 1997, which Saa himself confirmed in his own complaint. If it were a genuine error, his DTR should have reflected leave for both June 25 and 26, which it did not.
The legal logic rests on the high standard of integrity demanded of court personnel, especially a Clerk of Court. As an officer essential to the judicial system, a Clerk of Court must be a person of competence, honesty, and probity, tasked with safeguarding the integrity of court records and proceedings. Falsifying a DTR constitutes dishonesty and gross misconduct, as it involves making an untruthful statement in a narrative of facts within the context of an official document. Such act violates the norm of public accountability and diminishes public faith in the judiciary. While his claimed circumstances might mitigate liability, they do not exonerate him. Accordingly, the Court imposed a fine of Five Thousand Pesos (₱5,000.00) with a stern warning.