A.M. No. P-04-1838. August 31, 2006.
Re: Audit Report on Attendance of Court Personnel of Regional Trial Court, Branch 32, Manila.

FACTS

An audit was conducted on April 23, 2002, at the Regional Trial Court, Branch 32, Manila, after a Deputy Court Administrator found only one employee present during an official visit. The audit team examined the attendance logbook and compared it with the submitted Daily Time Records (DTRs). The investigation revealed that several court personnel, namely Loida Moralejo (Officer-in-Charge), Heidwig Marie O. Balicanta (Clerk III), Elma Dabbay (Court Stenographer III), Virginia Peralta (Court Stenographer), Paquito del Rosario (Court Aide), and Andresito Robles (Process Server), had failed to log their attendance in the official logbook on specific dates. Despite these omissions, their corresponding DTRs, which were signed by the OIC and the presiding judge, indicated either perfect attendance or minimal tardiness for those same periods. In their explanations, the respondents admitted the lapses but claimed they were done in good faith, without intent to deceive, and were merely honest mistakes or misinterpretations of the rules.

ISSUE

Whether the respondents are administratively liable for their failure to log their attendance in the official logbook while reporting present in their DTRs for the same periods.

RULING

Yes, the respondents are guilty of Dishonesty. The Supreme Court emphasized that the act of indicating presence in a DTR despite a failure to log in the official attendance record constitutes falsification of an official document. The legal logic is grounded in the principle that court personnel are bound by stringent standards of honesty and integrity, as the judiciary’s credibility depends on the conduct of its employees. The claim of good faith or honest mistake was rejected. The Court ruled that the consistent failure to log in, coupled with the submission of DTRs reflecting contrary information, cannot be deemed mere negligence; it is a deliberate act that misrepresents the truth. The DTR is an official document required by civil service rules, and its inaccuracy undermines administrative integrity. The varying penalties (fines of P5,000.00 for Moralejo, Balicanta, Dabbay, and Peralta; P2,000.00 for del Rosario and Robles) reflect the differing degrees of frequency and responsibility, with the OIC held to a higher standard. Presiding Judge Juan C. Nabong, Jr. was separately fined for failure to exercise proper supervision. The Court sternly warned that repetition would be dealt with more severely, underscoring that such infractions erode public trust in the judicial system.