A.M. No. P-16-3490, August 30, 2016
JUDGE FE GALLON-GAYANILO, Complainant vs. ERIC C. CALDITO, Process Server, Branch 35, Regional Trial Court, Iloilo City, Iloilo, Respondent

FACTS

Judge Fe Gallon-Gayanilo filed a complaint against Eric C. Caldito, a Process Server in her court, for Dishonesty and Gross Misconduct. The complaint alleged that Caldito falsified a court order dated February 27, 2014, in Cadastral Case No. 14-479. The original order merely directed the amendment of a petition. However, Caldito altered it by copying contents from an order in a different case to make it appear that the petition was set for hearing on May 22, 2014, and that he was directed to post notices. The actual hearing was scheduled for June 5, 2015, per a subsequent order. Caldito then presented this falsified order to the law firm handling the case to solicit PHP 1,000.00 for purported posting expenses.
When directed by the Branch Clerk of Court to comment on the allegation, Caldito did not file a reply and instead went on absence without leave (AWOL). The Office of the Court Administrator (OCA) subsequently directed him to comment on the formal complaint. Caldito, however, submitted a letter of resignation dated May 12, 2014, which was later accepted effective the same date, subject to clearance. Despite further directives and a tracer from the OCA, Caldito never submitted his comment or answered the charges against him.

ISSUE

Whether respondent Eric C. Caldito is administratively liable for Grave Misconduct, Falsification, and Dishonesty.

RULING

Yes, the Supreme Court found respondent guilty as charged. The legal logic is anchored on the high ethical standards mandated for court personnel under the Code of Conduct for Court Personnel. Canon IV, Section 3 explicitly prohibits court personnel from altering or falsifying any record within their control. Caldito’s act of falsifying a court order to solicit money from a party with a pending case constitutes Grave Misconduct, as it involves a clear intent to violate the law and a flagrant disregard of established rules. His actions directly undermined the integrity of the judicial process.
The Court emphasized that resignation does not preclude administrative liability, nor does it absolve an erring employee from the consequences of their actions. Caldito’s failure to comply with the OCA’s directives to comment further demonstrated willful disrespect for lawful orders and the Court’s administrative authority. Given the gravity of the offenses and the absence of any mitigating circumstance—such as remorse, acknowledgment of infractions, or length of service—leniency was unjustified. His resignation was deemed a tactic to evade administrative sanction.
Consequently, the Court imposed the accessory penalties of forfeiture of all retirement benefits, except accrued leave credits, and perpetual disqualification from re-employment in any government branch, instrumentality, or government-owned and controlled corporation. The OCA was also directed to file the appropriate criminal complaint against the respondent. This decision reinforces the principle that conduct which violates public accountability and diminishes public faith in the justice system will be met with the severest penalties.