A.M. No. 02-8-23-0 February 16, 2005
Re: Fake Decision Allegedly in G.R. No. 75242

FACTS

This administrative matter originated when Dario G. Silvestre of the Development Bank of the Philippines furnished the Supreme Court with documents pertaining to an alleged case, G.R. No. L-75242, entitled “University of the Philippines, et al. vs. St. Mary Crusade to Alleviate Poverty of Brethren Foundation, Inc.” The submitted packet included a purported two-page Supreme Court Decision dated May 19, 2000, a Resolution dated March 2, 2000, a Notice of Resolution, and a Certification dated August 14, 2000, all bearing the forged signatures of Chief Justice Hilario G. Davide, Jr. and several Associate Justices. The documents also included a letter and a certification fraudulently attributed to then-Clerk of Court Luzviminda D. Puno. The fake decision purported to affirm a lower court’s ruling ordering the registration of a 430-hectare parcel of land in Quezon City in favor of the St. Mary Crusade Foundation.
Upon investigation, the Court found that the docket number G.R. No. 75242 was actually assigned to an entirely different case, “Manila Resource Development Corporation vs. National Labor Relations Commission,” which had long been terminated. Furthermore, no case with the title “University of the Philippines vs. St. Mary Crusade…” existed in the Court’s records. The documents were conclusively established as fabrications.

ISSUE

The primary issue was the appropriate administrative and legal response to the discovery of falsified Supreme Court documents being used to support a fraudulent land registration claim.

RULING

The Supreme Court, acting to protect the integrity of the judicial process and its official records, ordered a comprehensive investigation and authorized the filing of criminal charges. The legal logic is rooted in the Court’s inherent power and duty to preserve the sanctity of its processes and official issuances. The fabrication of court decisions and resolutions constitutes a direct assault on the judiciary’s authority, undermines public confidence in the legal system, and facilitates fraud against parties and the government. The Court emphasized that such acts are not merely administrative infractions but are criminal in nature, involving falsification of public documents under the Revised Penal Code.
Consequently, the Court resolved to: (1) direct the National Bureau of Investigation (NBI) to reopen and expedite its investigation into the forgery; (2) order various court officials, including the Clerk of Court and the Chief Reporter, to issue certifications on the non-existence of the fake case to aid the NBI; and (3) enjoin all court personnel to cooperate with the investigation. The Court also amended a prior resolution to formally designate the Clerk of Court en banc as the complainant for any criminal case to be filed against the perpetrators, including Teodora Villanueva, Jaime Borjal, and Felicisimo Arellano. This systematic approach ensures that the full force of the law is applied to deter future attempts to misuse the Court’s name and authority for illicit purposes.