A.M. No. P-08-2549; June 18, 2010
Anonymous, Complainant, vs. Emma Baldonado Curamen, Court Interpreter I, Municipal Trial Court, Rizal, Nueva Ecija, Respondent.

FACTS

The Office of the Court Administrator received an anonymous complaint charging respondent Court Interpreter I with dishonesty and falsification of a public document. The complaint alleged that respondent registered the birth of a child named Rica Mae Baldonado Curamen, falsely representing herself and her husband as the biological parents. An investigation by the Executive Judge confirmed that the child was actually respondent’s granddaughter, Rinea Mae Curamen Aquino, whose true parents are spouses Olga Mae Baldonado Curamen Aquino and Jun Aquino. The child’s legitimate birth was already registered in Cabanatuan City in 2005.
Respondent admitted the true parentage but claimed the child’s unemployed parents proposed the re-registration for support reasons, asserting it was a common familial practice without intent to conceal. She denied the separate allegation of listing the child as an additional dependent in her income tax return.

ISSUE

Whether respondent is administratively liable for her actions concerning the falsified birth certificate and alleged false income tax declaration.

RULING

The Supreme Court found respondent guilty of dishonesty and falsification of a public document. Regarding the tax allegation, the Court ruled no evidence substantiated the claim that respondent listed the child as a dependent; complainant bore the burden of proof and failed to provide convincing evidence.
However, for the falsified birth certificate, the Court held respondent liable. A birth certificate is a public document serving as prima facie evidence of filiation. Making a false statement therein constitutes dishonesty and falsification. The Court rejected respondent’s justification that she acted to help support the family, noting such reasoning was illogical and an affront to common sense. The intent to injure a third party is not required for liability; the violation of public faith and the destruction of truth in the document are the principal offenses punished. As a court employee, respondent’s private acts reflecting on her integrity are subject to discipline.
While dishonesty and falsification are grave offenses punishable by dismissal, the Court considered the mitigating circumstance of it being respondent’s first offense in the interest of substantial justice. Consequently, the penalty was reduced to suspension for six months and one day without pay, with a stern warning against repetition. Copies of the resolution were ordered furnished to the Provincial Prosecutor for possible cancellation of the falsified birth record.