G.R. No. P-08-2573. June 19, 2012
OFFICE OF THE COURT ADMINISTRATOR, Complainant, vs. JAIME P. KASILAG, Sheriff IV, Regional Trial Court, Branch 27, Manila, Respondent.

FACTS

This administrative case arose from the alleged tampering of the Daily Time Record (DTR) of respondent Sheriff Jaime P. Kasilag for February 2004. The Office of the Court Administrator (OCA), upon review, noted apparent “superimpositions” on the DTR. Victor Y. Serapio, Officer-in-Charge of the RTC, confirmed discrepancies between Kasilag’s DTR and the official Daily Time Registry Book. Serapio reported that Kasilag had taken a six-day leave, but the DTR showed erasures and replacements with time entries falsely indicating he reported for work on those days. Serapio recommended disciplinary action.
Despite repeated directives from the Court starting July 2004, Kasilag persistently failed to file his required Comment. He resigned effective February 1, 2007. The Court subsequently found him in contempt for his non-compliance, imposing a fine. Kasilag filed a Motion for Reconsideration, claiming an inability to recall events and lack of access to the complaint documents, but again failed to submit his Comment after the Court granted him a final opportunity. The OCA also noted Kasilag’s prior record of habitual tardiness, absences, and failure to file required reports.

ISSUE

Whether respondent Jaime P. Kasilag is administratively liable for falsifying his Daily Time Record and for repeated failure to comply with the Court’s lawful orders.

RULING

Yes, respondent is administratively liable. The Court found substantial evidence, through the certified documents and Serapio’s report, that Kasilag falsified his February 2004 DTR. Falsification of an official document is a grave offense under Civil Service rules, constituting dishonesty. Both offenses are punishable by dismissal even for a first offense. The act undermines public accountability and integrity, core principles under the Constitution which enshrines public office as a public trust.
The Court exercises its administrative jurisdiction over Kasilag notwithstanding his resignation. Resignation does not absolve a public officer from administrative liability incurred during service. While dismissal is now moot, the Court can impose other penalties such as forfeiture of benefits and disqualification from reemployment. Kasilag’s blatant disregard of the Court’s orders to file his Comment, spanning years and continuing even after a contempt finding, compounds his liability. It demonstrates a disrespect for judicial processes and a failure to uphold the duty of every court employee to obey lawful directives. His excuses for non-compliance were deemed flimsy and dilatory. His prior record of infractions further reflects poorly on his fitness for public service. Accordingly, the Court found him guilty of dishonesty and gross insubordination, warranting severe sanctions.