AM P 02 1559; (May, 2002) (Digest)
G.R. No. P-02-1559, May 28, 2002
Rosario S. Panuncio vs. Oscar T. Espiritu, Clerk III, Regional Trial Court, Pasig City, Branch 165
FACTS
This administrative case originated from a complaint filed by Rosario Panuncio with the Office of the Ombudsman against NBI agents for unlawful arrest. Panuncio was arrested in November 1994 based on a 1989 warrant from RTC-Pasig, Branch 165, in a murder case. She presented a 1989 court order recalling that warrant. To verify, NBI agents brought her to the court, but respondent Oscar Espiritu, the criminal records custodian, could not locate the case records. Verification with the Prosecutor’s Office revealed the case had been dismissed in 1989, leading to Panuncio’s release. The Ombudsman dismissed the complaint against the NBI agents but, upon finding the court records missing, recommended charging Espiritu with Infidelity in the Custody of Documents and referred the matter to the Supreme Court for administrative action.
ISSUE
Whether respondent Oscar Espiritu is administratively liable for the loss of the court records under his custody.
RULING
Yes, respondent is administratively liable for neglect of duty. The Court agreed with the Office of the Court Administrator’s recommendation. As the designated custodian, Espiritu had a non-delegable duty to exercise diligence, efficiency, and professionalism in safeguarding court records. His excuses—that the records were lost during a court transfer in 1991 and that the storage cabinets lacked locks—were deemed untenable. The transfer of sala did not absolve him; he should have implemented measures to ensure the secure transfer and storage of all records. His failure to report the lack of secure storage to his superiors or to seek solutions demonstrated a lack of due diligence.
Court records are confidential documents vital to the administration of justice. Every court officer must uphold the highest standards of responsibility, and their conduct must be above suspicion. By failing to provide a satisfactory explanation for the loss and not exercising reasonable skill in his duties, Espiritu violated this standard. Accordingly, the Court imposed a fine of One Thousand Pesos (P1,000.00) for neglect of duty, with a warning that a repetition would be dealt with more severely.