G.R. No. P-02-1556. February 22, 2002
NORMA SANTOS, complainant, vs. JOYCE TRINIDAD ARLEGUI-HERNANDEZ, Clerk of Court, Metropolitan Trial Court, Branch 58, San Juan, Metro Manila, and Atty. MARLON B. LLAUDER, private practitioner, respondents.

FACTS

Complainant Norma Santos was a defendant in an ejectment case. She received the summons and complaint on June 7, 1994, and noted the complaint lacked the required certification against forum shopping under Administrative Circular No. 04-94. She raised this deficiency in her Answer. After an adverse decision, she appealed. While preparing her petition for the Court of Appeals, she discovered a certification against forum shopping had been inserted into the case records. This certification was undated, bore a notarial date of June 8, 1994, and lacked the court’s “RECEIVED” stamp. Complainant alleged respondent Clerk of Court, Joyce Trinidad Arlegui-Hernandez, connived with the plaintiff’s counsel to intercalate this document to cure a fatal defect in the initiatory pleading.
Respondent Hernandez denied the allegations. She claimed the certification was already part of the records when the complaint was filed and that it was served upon the defendants. She argued the issue of intercalation was not raised during the preliminary conference or the appeal to the Regional Trial Court, implying it was a belated strategy. The case was referred for investigation, which found respondent guilty of negligence.

ISSUE

Whether respondent Clerk of Court is administratively liable for her actions concerning the certification against forum shopping.

RULING

Yes, respondent is guilty of grave misconduct and conduct prejudicial to the best interest of the service. The Supreme Court found the investigating judge’s recommendation of a mere reprimand too light. The legal logic rests on the Clerk of Court’s vital role as custodian of court records and an officer of the court. Her duty is to ensure the integrity and sanctity of court documents. The certification in question was irregular: it was undated, not stamped “RECEIVED,” and its notarization date was after the complaint’s filing. By allowing or effecting its insertion to retroactively cure a jurisdictional defect, respondent committed an act of dishonesty that compromised the court records’ reliability.
This act constitutes grave misconduct, as it undermines public faith in the judiciary’s integrity. The Court emphasized that dishonesty in the performance of official duties, especially by a court employee charged with safeguarding records, is a severe offense that warrants a stern penalty. The Court distinguished this from simple negligence, finding the act intentional and deceptive. Consequently, the Court imposed a one-year suspension with a stern warning, deviating from the lighter recommendations, to uphold the highest standards of conduct required from court personnel.