ADM. MATTER No. P-04-1779, November 25, 2005
EXECUTIVE JUDGE MENRADO V. CORPUZ, Complainant, vs. MAX RAMITERRE, Civil Docket Clerk, and VIRGILIO T. BUNAO, JR., OIC-Branch Clerk of Court, Respondents.

FACTS

This administrative case originated from an allegation by a provincial prosecutor regarding an anomaly in LRC Case No. 181 for reconstitution of title before the RTC of Cabarroguis, Quirino. The prosecutor discovered a January 17, 1997 Order granting the petition, despite no hearing having been conducted and the signature of the then-presiding Judge, Wilfredo P. Ambrosio, being forged, as confirmed by the Judge himself. The matter was investigated by Executive Judge Menrado Corpuz.
Judge Corpuz’s investigation revealed that respondent Max Ramiterre, the civil docket clerk, assumed his post in late January 1997 and inventoried the cases. LRC Case No. 181 was pending. In 1999, a new presiding judge ordered all pending cases set for hearing. Before the scheduled hearing, the petitioner, Rolando Dapon, informed Ramiterre the case was already finished and he had obtained a loan using the reconstituted title. Dapon later furnished Ramiterre a copy of the January 1997 Order, which Ramiterre attached to the records. Ramiterre testified he believed the Judge’s signature on the Order was fake but did not report it, relying on Dapon’s representation and the document’s court seal. Respondent Virgilio Bunao, Jr., the OIC-Branch Clerk of Court, claimed unfamiliarity with land registration procedures.

ISSUE

Whether respondents Max Ramiterre and Virgilio Bunao, Jr. are administratively liable for their actions concerning the forged court order in LRC Case No. 181.

RULING

The Court found Max Ramiterre guilty of Dishonesty and dismissed him from service. The ruling is anchored on his gross neglect of duty and failure to uphold the integrity of court processes. As the assigned civil docket clerk, Ramiterre had direct custody and responsibility over the case records. His admission that he suspected the judge’s signature was forged yet chose not to verify or report it to his superiors constitutes dishonesty. By attaching the spurious order to the record and subsequently reporting the case as terminated in official monthly and semestral reports, he actively facilitated the fraud and made it appear official. His inaction and subsequent acts were not mere negligence but a conscious disregard of his duty, which compromised the court’s integrity.
In contrast, the case against Virgilio Bunao, Jr. was dismissed for lack of sufficient evidence. While his designation as OIC-Branch Clerk of Court carried responsibilities, the Court found his defense of unfamiliarity with the specific procedures for land registration cases credible, given his background as a court interpreter and the lack of evidence showing he had actual knowledge of the forgery or participated in the cover-up. His directive to set the case for hearing was a routine compliance with the judge’s order and did not, by itself, establish complicity in the dishonesty. The penalty for Ramiterre reflects the Court’s stringent standard that dishonesty, which erodes public trust in the judiciary, warrants the ultimate penalty of dismissal.