G.R. No. A.M. No. P-15-3321. October 21, 2015.
REGINA GUIAWAN BALANZA, Complainant, vs. ARSENIO P. CRISTE, CLERK III, REGIONAL TRIAL COURT, BRANCH 21, VIGAN CITY, ILOCOS SUR, Respondent.

FACTS

Complainant Regina Guiawan Balanza, the respondent in Civil Case No. 5913-V for Declaration of Nullity of Marriage, filed an administrative complaint against Arsenio P. Criste, Clerk III of the RTC, Branch 21, Vigan City, Ilocos Sur, for Grave Misconduct, Dishonesty, Infidelity in Custody of Judicial Records, and Acts Prejudicial to the Service. Regina alleged that Criste, in cohort with her husband Roy Balanza, falsified or forged a Decision dated April 14, 2008, and a Certificate of Finality in the said civil case, despite the case not yet being submitted for decision and without the knowledge of the Presiding Judge or Branch Clerk of Court. The spurious documents were circulated to civil registrar offices and used by Roy to contract another marriage during the pendency of the case. The Presiding Judge later disowned the Decision in an Order dated August 8, 2008.
In his Answer, Criste denied the charges, claiming they were speculative and lacked direct evidence. He asserted that Regina had extrajudicially settled the civil aspect of the case, receiving ₱380,000 from Roy, and agreed to submit the case for resolution. Criste stated he found the alleged Decision on his table and, believing it to be genuine, authenticated photocopies as “true copy on file.” He attributed Regina’s complaint to her desire to extract more money from Roy.
The case was referred for investigation. During proceedings, Regina and Roy entered into a Compromise Agreement regarding support for their daughter, leading Regina to execute an Affidavit of Desistance, withdrawing her complaint due to “miscommunication or honest misapprehension of facts.” However, the investigating executive judge and the Office of the Court Administrator (OCA) proceeded with the evaluation. The OCA found Criste guilty of Dishonesty for authenticating the spurious documents, taking undue interest in the case due to his acquaintance with Roy, and failing to satisfactorily explain his possession of the falsified Decision. The OCA recommended a six-month-and-one-day suspension, but since Criste had retired on December 1, 2014, it proposed a fine equivalent to his salary for that period.

ISSUE

Whether respondent Arsenio P. Criste is administratively liable for Dishonesty in relation to the falsified Decision and Certificate of Finality in Civil Case No. 5913-V.

RULING

Yes, the Court found Arsenio P. Criste guilty of Serious Dishonesty. The Court held that substantial evidence—defined as such relevant evidence as a reasonable mind might accept as adequate to support a conclusion—established Criste’s culpability. Despite Regina’s desistance, the evidence showed that Criste authenticated photocopies of the spurious Decision and Certificate of Finality by signing them as “true copy on file,” an act beyond his authority as a civil docket clerk. His explanation that he found the documents on his table and believed them to be genuine was deemed unsatisfactory and indicative of dishonesty, defined under Civil Service rules as “concealment or distortion of truth” showing intent to deceive.
The Court classified the offense as Serious Dishonesty under Section 3(e) of CSC Resolution No. 06-0538, as amended, for employing fraud or falsification of official documents related to employment. The penalty for Serious Dishonesty is dismissal, but considering mitigating circumstances—Criste’s 41 years of unblemished service, first offense, and financial dependence on retirement benefits—the Court imposed a fine equivalent to his salary for six months and one day. The Finance Division was directed to release the balance of his retirement benefits after deducting the fine.