AM P 09 2621; (September, 2016) (Digest)

G.R. No. P-09-2621. September 20, 2016
OFFICE OF THE COURT ADMINISTRATOR, COMPLAINANT, VS. EDUARDO T. UMBLAS, LEGAL RESEARCHER, REGIONAL TRIAL COURT, BRANCH 33, BALLESTEROS, CAGAYAN, RESPONDENT.

FACTS

Complainant Maria Noemi Bautista-Pabon discovered that her estranged husband, Ramil Pabon, had submitted to a prosecutor’s office a purported June 20, 2005 RTC Decision penned by Judge Eugenio Tangonan, Jr., declaring their marriage null and void, along with a corresponding Certificate of Finality dated December 18, 2005. Both documents were stamped “Certified True Copy” and bore the signature of respondent Eduardo T. Umblas, a Legal Researcher at RTC Branch 33 in Ballesteros, Cagayan. Noemi, who was then living with Ramil in Batangas, verified with the OSG and found no record of the case. She then went to the RTC in Ballesteros, where court personnel confirmed no such case was docketed. Umblas refused to confirm the case’s existence or provide records. The Office of the Court Administrator (OCA) subsequently filed an administrative complaint against Umblas for Grave Misconduct and violation of the Code of Conduct and Ethical Standards for Public Officials and Employees (R.A. No. 6713).
In his defense, Umblas denied issuing the documents, claiming his signatures were forged and that the lack of proof of payment for the Certificate of Finality indicated fraud. He argued that Ramil, as the possessor and beneficiary of the documents, should be presumed their author. The case underwent several reassignments due to inhibitions by investigating judges. The OCA, in its report, found the documents spurious, noting multiple procedural anomalies: the case number was non-standard, no records existed, and mandatory notices to the OSG and public prosecutor for a nullity case were absent.

ISSUE

Whether respondent Eduardo T. Umblas is administratively liable for Grave Misconduct for certifying a spurious court decision and certificate of finality.

RULING

Yes, the Supreme Court found respondent Eduardo T. Umblas guilty of Grave Misconduct and dismissed him from service. The legal logic rests on the conclusive evidence that the documents were fabricated and that Umblas’s certification constituted a deliberate falsity. First, the investigation confirmed the non-existence of Civil Case No. 33-328C-2005 in the court’s docket, a fact attested by the Clerk of Court. Second, the purported decision itself contained fatal procedural defects, such as the failure to serve copies on the Office of the Solicitor General and the public prosecutor as required by A.M. No. 02-11-10-SC (Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages). These mandatory steps ensure state intervention to prevent collusion, and their absence confirmed the document’s illegitimacy.
The Court rejected Umblas’s defense of forgery. As the legal researcher who certified the documents, he bore the burden of proving the signatures were not his. He failed to present any evidence, such as a handwriting expert’s testimony or exemplars for comparison, to substantiate his claim. His mere denial could not overcome the presumption that the official duty of certification was regularly performed. By affixing his certification to patently spurious documents, Umblas engaged in conduct that was intentional, dishonest, and aimed at deceiving the public and the legal system. Such an act constitutes Grave Misconduct, defined as a wrongful intention coupled with a transgression of established rules. It underm