G.R. No. A.M. No. 93-10-1269-RTC. July 8, 1994. ATTY. ARTEMIO D. CAÑA, complainant, vs. BELEN D. SANTOS, Stenographic Reporter of Regional Trial Court, Branch 6, Malolos, Bulacan, respondent.
FACTS

This administrative case originated from a letter-report by Acting Register of Deeds Atty. Artemio D. Caña, concerning a spurious Order dated September 25, 1992, purportedly issued by Judge Camilo D. Montesa, Jr. of RTC Branch 19, Malolos, for the reconstitution of a certificate of title. The fake order was presented to the Register of Deeds by Enrico Fombo, who received it from Gerardo Flores, the attorney-in-fact for the petitioner in the reconstitution case. Investigation revealed that Flores obtained the order from respondent Belen Santos, a stenographic reporter of RTC Branch 6. Further inquiry confirmed no such order was issued by Judge Montesa. Subsequently, two other fake orders dated February 15, 1993, also linked to Flores, were discovered in separate reconstitution cases.
The Criminal Investigation Service filed an Information for falsification of public documents against Santos. In the administrative proceeding, Santos filed an unsigned comment denying the charges, claiming she had no involvement as she was not a personnel of Branch 19 and was unaware of the orders’ authenticity. She also argued the case was moot due to the withdrawal of the criminal complaint by Flores and Alfredo de Guzman after an amicable settlement.

ISSUE

Whether respondent Belen D. Santos should be held administratively liable for her involvement in the transactions concerning spurious court orders.

RULING

Yes, respondent is administratively liable and is dismissed from service. The Court adopted the findings of the investigating judge, which established that Santos was the person who procured and gave the fake orders to Gerardo Flores, as affirmed by the sworn statements of Flores and de Guzman. While the records did not concretely prove she authored the falsified documents, her active participation in the illicit transactions for monetary consideration was substantiated.
The legal logic is grounded on the high standard of conduct required from all judiciary personnel. By involving herself in a scheme to use spurious court orders for reconstitution of titles, Santos engaged in dishonesty and conduct prejudicial to the service, violating the integrity and dignity of the courts. The Court emphasized that public servants must avoid any financial dealings that interfere with their duties. Furthermore, the withdrawal of the criminal complaints did not bar the administrative case. Desistance by private complainants cannot divest the Court of its jurisdiction to investigate and discipline its employees, as the Court has an inherent interest in maintaining the conduct and integrity of the judiciary. Thus, dismissal with forfeiture of benefits and disqualification from re-employment in government is warranted.