A.M. No. P-19-4001, April 02, 2025
Almyra D. Yap, Librarian, Regional Trial Court, Angeles City, Pampanga, Complainant, vs. Nida Gonzales, Legal Researcher, Branch 56, Same Court, Respondent.

FACTS

This administrative case originated from a separate complaint filed against respondent Nida Gonzales, a Legal Researcher, before the Office of the Court Administrator (OCA). In relation to that prior case, Gonzales approached complainant Almyra D. Yap, a court librarian, to execute an affidavit. Gonzales volunteered to draft the document for Yap. Subsequently, Yap discovered that Gonzales had prepared, signed in Yap’s name, had notarized, and submitted an affidavit dated October 26, 2017, to the OCA without Yap’s knowledge or consent. Yap then filed the instant complaint for this act.
In her Comment, Gonzales admitted to preparing, signing, and having the affidavit notarized without Yap’s knowledge. She claimed she was pressed for time to file her comment in the prior administrative case and acted in good faith to explain the circumstances surrounding her employment of certain individuals. The OCA found her guilty of Simple Misconduct and recommended a suspension of one month and one day to six months.

ISSUE

Whether respondent Nida Gonzales should be held administratively liable for her actions.

RULING

Yes, the Court found respondent GUILTY of Serious Dishonesty and Falsification of an Official Document. The Court concurred with the OCA’s finding of liability but modified the designation of the offense and the penalty. Gonzales’s own admissions established that she affixed Yap’s purported signature to the affidavit and had it notarized. This act constitutes Falsification of an Official Document, defined as knowingly making false statements in an official document. Furthermore, by deliberately submitting this falsified document to the OCA as part of her defense in an administrative case, she committed Serious Dishonesty, which involves the use of falsification in a dishonest act related to her employment.
Both offenses are classified as serious charges under Section 14 of Rule 140 of the Rules of Court, as amended. For such serious charges, Section 17 prescribes the penalty of dismissal from service, forfeiture of benefits (except accrued leave credits), and disqualification from re-employment in any government office. The Court emphasized that the act of falsifying a public document and submitting it to a judicial office strikes at the very heart of the integrity demanded of court personnel. Good faith is not a defense, as the act itself was intentional and patently dishonest. Accordingly, the Court dismissed Nida Gonzales from service with all its attendant penalties.