G.R. No.: A.M. Nos. P-96-1229-30
Date: March 25, 2002

Case Parties: Office of the Court Administrator, complainant, vs. Atty. Paulino I. Saguyod, Branch Clerk of Court, and Rener L. Antonio, Clerk III, RTC, Branch 67, Paniqui, Tarlac, respondents.

FACTS

1. On December 15, 1994, the RTC of Angeles City, Branch 59, received an Order of Release for accused Rolando Gaudia, allegedly signed by Judge Dario R. Navarro of RTC, Branch 67, Paniqui, Tarlac, based on a purported bail bond from Commonwealth Insurance Company. No copy of the bond was attached.
2. Acting Presiding Judge Eli G.C. Natividad of Branch 59 ordered Atty. Paulino I. Saguyod, Branch Clerk of Court of Branch 67, to transmit the surety bond and pertinent papers. Atty. Saguyod failed to comply.
3. After repeated failures, the regular Presiding Judge of Branch 59, Judge Eliezer delos Santos, required Atty. Saguyod to show cause why he should not be held in contempt. Commonwealth Insurance Company informed the court it did not issue the bail bond and had stopped issuing bail bonds since 1992.
4. In his explanation, Atty. Saguyod alleged he had not seen the earlier orders as he was on official leave and that Rener L. Antonio, Clerk-in-Charge of Criminal Cases, received the bail bond and facilitated the Order of Release.
5. Judge delos Santos found the explanation unsatisfactory, cited Atty. Saguyod in contempt, and later denied his motion for reconsideration. The matter was referred to the Office of the Court Administrator (OCA).
6. An investigation by Judge Angel J. Parazo revealed that:
a. Rener L. Antonio received the orders from Branch 59 but kept them and failed to give them to Atty. Saguyod.
b. Antonio asked for Gaudia’s warrant of arrest, typed a bail bond using Commonwealth Insurance Company’s form, prepared the Order of Release, and misled Judge Navarro into approving the fake bond and signing the release order.
c. Antonio received P5,000.00 from Gaudia for facilitating the release.
d. Atty. Saguyod, upon learning of the irregularities, merely issued an administrative order requiring Antonio to explain and took no further action.
7. The OCA filed separate administrative complaints: against Atty. Saguyod for Falsification of Official Document and Neglect of Duty (A.M. No. P-96-1229), and against Antonio for Dishonesty, Gross Misconduct and Falsification of Official Document (A.M. No. P-96-1230).
8. During the pendency of the case, Antonio resigned (effective June 2, 1997) and later died on September 24, 2000.

ISSUE

1. Whether Atty. Paulino I. Saguyod is administratively liable for his actions and inactions in relation to the fraudulent release order and his supervision of staff.
2. Whether Rener L. Antonio is administratively liable for his role in the fraudulent release order, notwithstanding his subsequent resignation and death.

RULING

1. As to Atty. Paulino I. Saguyod: The Court found him administratively liable for negligence in the performance of his duties. He took 42 days to comply with the orders from Branch 59 and, upon learning of Antonio’s irregularities, merely issued an administrative order without taking further action. The Court emphasized that a Clerk of Court is a vital officer in the judicial system, required to be competent, honest, and imbued with the duty to safeguard the integrity of court proceedings. His failure to act promptly and decisively warranted sanction. He was REPRIMANDED and ordered to pay a FINE of One Thousand Pesos (P1,000.00), with a stern warning that repetition would be dealt with more severely.
2. As to Rener L. Antonio: The Court found him guilty of dishonesty and serious misconduct prejudicial to the service. His actions—preparing a fake bail bond, misleading a judge into signing a release order, and receiving money for the facilitation—were grave offenses. The Court held that his death did not preclude the imposition of administrative sanctions, as the case had already been investigated and the facts established. He was ordered to pay a FINE of Ten Thousand Pesos (P10,000.00), to be deducted from any benefits due to his estate.