A.M. No. 20-06-18-MCTC, September 29, 2020
RE: FINAL REPORT ON THE FINANCIAL AUDIT CONDUCTED IN THE MUNICIPAL CIRCUIT TRIAL COURT, VALLADOLID-SAN ENRIQUE-PULUPANDAN, NEGROS OCCIDENTAL

FACTS

A financial audit was conducted on the Municipal Circuit Trial Court (MCTC) of Valladolid-San Enrique-Pulupandan, Negros Occidental, covering the accounts of three accountable officers: George E. Santos (retired), Ignacio D. Denila (resigned), and John O. Negroprado (incumbent Clerk of Court II). The audit was prompted by Negroprado’s persistent failure to submit his mandatory monthly financial reports for various judiciary funds, leading to the withholding of his salaries since 2009. The audit revealed significant shortages across several funds under Negroprado’s accountability from 2003 to 2013, specifically: a Fiduciary Fund shortage of P252,500.00; a Judiciary Development Fund (JDF) shortage of P93,304.50; a Special Allowance for the Judiciary Fund (SAJF) shortage of P152,105.50; a Mediation Fund shortage of P44,000.00; and a minor Clerk of Court General Fund shortage of P106.00, totaling P542,015.80. Negroprado restituted these amounts only in 2019. In his defense, he cited financial distress from family medical expenses and loans.

ISSUE

Whether respondent John O. Negroprado should be held administratively liable for his failure to submit financial reports and for the shortages in the court’s fiduciary and special funds.

RULING

Yes, Negroprado is administratively liable. The Supreme Court emphasized that all court personnel must adhere to the highest standards of integrity and propriety, as their conduct directly impacts public trust in the judiciary. Negroprado violated specific circulars: Administrative Circular No. 35-2004, which requires immediate deposit of collections upon reaching P500.00, and OCA Circular No. 113-2004, which mandates the submission of sworn monthly reports by the 10th of the following month. His prolonged failure to submit reports and his misappropriation of court funds constituted gross dishonesty and grave misconduct. The Court found the OCA’s recommended fine of P25,000.00 insufficient, noting that the amount misappropriated was substantial (over half a million pesos) and was used for personal purposes. Applying precedent, the Court modified the penalty and imposed a fine of P50,000.00, to be deducted from his withheld salaries, with a stern warning. The ruling underscores that financial hardship does not excuse misappropriation of public funds, and clerks of court, as fiduciaries, bear the highest degree of responsibility in handling court collections.