A.M. No. 610-MJ. July 25, 1975.
George P. Suan, complainant, vs. Municipal Judge Delsanto Resuello of Allen, Northern Samar, respondent.

FACTS

Complainant George P. Suan charged respondent Municipal Judge Delsanto Resuello with multiple offenses, including gross negligence, falsification of Daily Time Records (DTRs), undue favoritism, interference in a criminal case, and being the subject of two criminal complaints. The respondent judge denied most charges, alleging they were fabricated by the complainant due to a pending theft case involving the complainant’s men. After a formal investigation, the Investigating Judge found the evidence insufficient to substantiate all charges except for the allegation regarding the falsification of DTRs.
The investigation revealed that the respondent judge uniformly prepared his DTRs to indicate service from 8:00 a.m. to 12:00 noon daily. Evidence established he had undertimes on specific dates, including July 11, 1969, August 8, 1969, August 19, 1969, and November 17, 1970, which were not reported. The respondent testified he believed that as long as he rendered the required four hours of service daily, the specific times recorded were a mere formality. He claimed to make up for morning undertimes by holding afternoon sessions, a statement uncontradicted by evidence.

ISSUE

Whether respondent Municipal Judge Delsanto Resuello is administratively liable for the manner in which he prepared his Daily Time Records.

RULING

Yes, the respondent judge is administratively liable for negligence. The Supreme Court rejected the respondent’s justification that accurately reporting arrival and departure times was a mere formality, provided the total required hours were met. The legal logic is grounded in the imperative of maintaining precise and truthful official records. Government circulars and civil service rules, specifically Department of Justice Circular No. 68 and Civil Service Form No. 48, mandate all officers to observe official hours and to keep a true and correct daily record of attendance. This requirement is of supreme importance for administrative integrity and accountability.
The Court emphasized that falsification or irregularities in time records render an officer liable for disciplinary action. While conceding the respondent may have acted in good faith without fraudulent intent, his persistent disregard for the precise recording requirement constituted imprudence and negligence in the performance of his duty. His belief did not excuse non-compliance with a clear administrative directive. Therefore, the Court found him administratively culpable. The more serious charges were dismissed for lack of proof, but for the DTR infraction, he was sentenced to pay a fine equivalent to one month’s salary and sternly warned that future violations would warrant more drastic sanctions.