AM 04 10 296 MTCc; (July, 2008) (Digest)
A.M. No. 04-10-296-MTCC; July 28, 2008
Report on the Attendance in Office of Mr. Glenn B. Hufalar, Municipal Trial Court in Cities, Branch 1, San Fernando City, La Union.
FACTS
This administrative case stemmed from a report by Executive Judge Eugenio A. Dacumos regarding the attendance of respondent Glenn B. Hufalar, a Process Server. The report detailed unreconciled entries between Hufalar’s Daily Time Records (DTRs) and the court’s official logbook for several months in 2003 and 2004. The logbook showed Hufalar was often absent, and when present, he frequently failed to indicate his time-out. He also did not file any leave of absence. The Clerk of Court had issued multiple memoranda to Hufalar concerning his improper attitude, non-declaration of absences, and failure to perform his duties, such as serving subpoenas. Despite these warnings and a subsequent order from another judge to explain his neglect, Hufalar failed to comply and eventually stopped reporting for work entirely on April 27, 2004.
The Office of the Court Administrator (OCA) found glaring discrepancies upon review. Hufalar’s DTRs showed whole-day attendance, but the court’s logbook reflected half-day absences or no record at all for those same days. The OCA concluded these acts amounted to tampering with and falsification of public documents. The Court required Hufalar to comment on the charges, sending notices to his home address. Despite receipt, he failed to file any comment or explanation in his defense.
ISSUE
Whether respondent Glenn B. Hufalar is administratively liable for Dishonesty and Absenteeism.
RULING
Yes, the Court found respondent guilty of both Dishonesty and Absenteeism. The legal logic is grounded in the fundamental standard of integrity required of all judiciary personnel. The comparison between the official logbook and Hufalar’s DTRs revealed intentional discrepancies; he recorded full-day attendance in his DTRs for days when the logbook showed he was absent or only present for half a day. This constitutes falsification of an official document, which is a clear act of dishonesty. His subsequent abandonment of his post, following a history of unexcused absences and neglect of duty, confirmed a pattern of absenteeism.
Due process was satisfied as Hufalar was given ample opportunity to be heard through the court memoranda and the Supreme Court’s directives to comment, all of which he ignored. His failure to contest the charges or explain the discrepancies constituted an admission of the facts. While the extreme penalty of dismissal was rendered moot by a prior resolution dropping him from the rolls for being absent without leave, the Court imposed the accessory penalties. Consequently, the Court ordered the forfeiture of all his benefits, except accrued leave credits, and perpetually disqualified him from reemployment in any government office. This serves to uphold the exacting standards of conduct demanded in the judiciary and to deter similar misconduct.
