G.R. No. A.M. No. P-13-3137. August 23, 2016.
OFFICE OF THE COURT ADMINISTRATOR, COMPLAINANT, VS. UMAIMA L. SILONGAN, ABIE M. AMILIL, AND SALICK U. PANDA, JR., RESPONDENTS.

FACTS

This administrative case stemmed from a prior investigation into spurious annulment decisions issued by Judge Cader P. Indar. The Supreme Court, having dismissed Judge Indar, directed the Office of the Court Administrator (OCA) to investigate respondents for their alleged participation. The fact-finding investigation revealed that numerous decisions certified by the respondents were non-existent in court records. Specifically, respondent Umaima L. Silongan, as Acting Clerk of Court, certified as true copies 27 decisions from Branch 14 and an order from Branch 15, none of which were docketed. She had also applied for separation benefits. Respondent Abie M. Amilil, an Officer-in-Charge, issued a Certificate of Finality and certified a decision for a case not found in the docket. Respondent Salick U. Panda, Jr., a former Clerk of Court, issued a Certificate of Finality for a purported nullity case, but the docket number actually corresponded to a foreclosure of mortgage case.
The case was referred to a Court of Appeals Justice for investigation. During the proceedings, Silongan and Amilil failed to appear despite notice and did not submit counter-affidavits. Only Panda appeared, claiming he signed the document in good faith upon Silongan’s assurance during his brief tenure. The Investigating Justice found all three administratively liable.

ISSUE

Whether respondents Umaima L. Silongan, Abie M. Amilil, and Salick U. Panda, Jr. are administratively liable for their acts of certifying non-existent court decisions and orders.

RULING

Yes, all respondents are administratively liable. The Court emphasized that clerks of court are essential officers tasked with safeguarding the integrity of court records. By certifying documents pertaining to non-existent cases, they committed acts of dishonesty and gross misconduct, which are grave offenses. Their certifications gave a false impression of authenticity to the spurious decisions, undermining public trust in the judiciary. The failure of Silongan and Amilil to participate in the investigation constituted a waiver of their right to contest the charges and was deemed an admission of the allegations.
The legal logic applied is that court personnel, as custodians of court records, bear a heavy responsibility to ensure the accuracy and existence of any document they authenticate. Certifying a non-existent judicial document is a blatant falsification that strikes at the very heart of judicial integrity. For Silongan, her active role and subsequent attempt to separate from service aggravated her liability. For Amilil, his issuance of a certification for a non-docketed case demonstrated gross neglect. For Panda, while he claimed good faith, his failure to verify the document before signing, a basic duty of a clerk of court, constituted simple neglect. Consequently, the Court dismissed Silongan from the service with forfeiture of all benefits and perpetual disqualification from reemployment. Amilil was similarly dismissed. Panda, having been separated from the judiciary, was fined P40,000, deductible from any accrued benefits.