GR 219062; (January, 2020) (Digest)
G.R. No. 219062 , January 29, 2020
Office of the Deputy Ombudsman for Mindanao, Petitioner, v. Antonieta A. Llauder, Respondent.
FACTS
Respondent Antonieta Llauder was an assistant registration officer at the Office of the Civil Registrar in Iligan City. A complaint was filed against her, the City Civil Registrar, and another officer for dishonesty and conduct prejudicial to the best interest of the service. The complaint alleged they conspired to register a spurious marriage certificate between complainant Benjamin Edmilao II and Mylain Chu. Edmilao claimed he signed a marriage license application as a “game play” for Chu to go abroad, upon his aunt’s promise it would not be registered. He later discovered a marriage certificate was registered, which indicated a solemnization date of July 30, 1997, while the notarization of the solemnizing officer’s oath was dated June 11, 1997—49 days prior. Llauder, on behalf of Chu, signed the application requesting the City Civil Registrar to indorse the documents for authentication. The marriage was later declared void by a Regional Trial Court. The Office of the Deputy Ombudsman found Llauder guilty of gross neglect of duty and conduct prejudicial to the best interest of the service, imposing a six-month suspension. The Court of Appeals modified this, finding her guilty only of simple neglect of duty with a three-month suspension. The Office of the Deputy Ombudsman filed this Petition for Review.
ISSUE
Whether the Court of Appeals erred in modifying the findings and penalty, and whether respondent Llauder is guilty of gross neglect of duty and conduct prejudicial to the best interest of the service.
RULING
Yes. The Supreme Court granted the petition and modified the Court of Appeals’ decision. The Court held that Llauder was guilty of gross neglect of duty and conduct prejudicial to the best interest of the service. Her duties as a registration officer were not merely ministerial; she was required to exercise due diligence in examining documents for registration. The glaring discrepancy between the notarization date and the marriage date on the certificate was a red flag that should have prompted further verification. Her failure to notice this and to ensure compliance with the required affidavits under Administrative Order No. 1, series of 1993, of the Office of the Civil Registrar General (for delayed registration of marriage) constituted gross negligence characterized by want of even slight care and blatant indifference to the consequences. This failure led to the registration of a spurious document, causing undue prejudice and undermining public trust in the civil registry system. The penalty of six months’ suspension imposed by the Office of the Deputy Ombudsman was reinstated.