A.M. No. P-17-3754. September 26, 2017. MARIA MAGDALENA R. JOVEN, JOSE RAUL C. JOVEN, AND NONA CATHARINA NATIVIDAD JOVEN CARNACETE, COMPLAINANTS, v. LOURDES G. CAOILI, CLERK OF COURT, MUNICIPAL TRIAL COURT IN CITIES, BRANCH 1, BAGUIO CITY, BENGUET, RESPONDENT.
FACTS

Complainants charged respondent Clerk of Court Lourdes G. Caoili with grave misconduct, impropriety, and conduct unbecoming a court employee. The complaint stemmed from the use by a certain Margarita Cecilia Rillera, an opposing party in various litigations with complainants, of a spurious “Unsigned Order of Dismissal” and transcript of stenographic notes (TSN) as evidence. These documents pertained to a dismissed civil case involving the parties’ predecessors-in-interest. Complainants alleged the documents were non-existent and fraudulent, and their use misled courts. A criminal complaint revealed, via Rillera’s Judicial Counter-Affidavit, that respondent was the source of these spurious documents. Complainants further alleged respondent provided improper assistance to Rillera, including securing court documents, releasing an unsigned order, and procuring lawyers, in exchange for monetary benefits and employment for her daughter.
In her defense, respondent admitted knowing Rillera but denied furnishing the unsigned order. She claimed she merely assisted Rillera in obtaining a TSN from another court by relaying a sealed envelope, which she did not open. She asserted her actions were not improper, as she had also assisted complainants on a prior occasion.

ISSUE

Whether respondent Lourdes G. Caoili is administratively liable for Grave Misconduct and Conduct Unbecoming a Court Personnel.

RULING

Yes, respondent is guilty as charged. The Supreme Court adopted the findings and recommendation of the Investigating Judge, which were based on a thorough investigation including subpoenaed witnesses. The investigation established that respondent indeed provided the fabricated unsigned order to Rillera, misrepresenting it as an advance copy from the presiding judge. She also gave Rillera updates and advice on the case and procured legal counsel for her. These acts constituted grave misconduct, defined as a wrongful intention coupled with a conscious disregard of duty. By actively assisting a party litigant in a pending case, providing a falsified court order, and receiving benefits, respondent exhibited corruption, a clear intent to violate the law, and a flagrant disregard of established rules. Her actions constituted serious transgressions of the exacting standards of integrity and propriety required of court personnel, eroding public trust in the judiciary’s impartiality. The Court noted her prior administrative liability for falsification of an official document, demonstrating a pattern of dishonorable conduct. Consequently, the penalty of dismissal from service, with forfeiture of benefits and disqualification from re-employment in any government agency, was imposed.