A.M. No. P-96. October 15, 1974. COURT OF INDUSTRIAL RELATIONS, complainant, vs. DEPUTY CLERK OF COURT JUAN C. REYES, respondent.
FACTS

The Acting Presiding Judge of the Court of Industrial Relations (CIR) formally charged Deputy Clerk of Court Juan C. Reyes with falsification. The charge stemmed from a jurat he administered on October 30, 1972, for a Verification attached to a Motion to Dismiss in an unfair labor practice case. The jurat made it appear that seven named officers of the complainant union personally appeared and swore before him. Subsequent sworn statements and a court order revealed that these affiants did not appear before him, leading to the motion’s denial. After investigation, the CIR’s designated investigator found that respondent Reyes had been misled by Bernardita Oracion, the union president whom he knew from a prior case. Oracion presented the already-signed motion with six other women, representing that they were the signatories. Reyes, trusting Oracion, administered the oath after all women raised their hands, but he failed to verify the genuineness of the signatures against any identification.
The Acting Presiding Judge of the CIR, adopting the investigator’s report, found respondent guilty of neglect of duty, not falsification, and imposed a penalty of reprimand with a stern warning. The Secretary of Justice, on appeal, increased the penalty to a three-month suspension without pay, reasoning that the neglect was not slight and that officers must diligently ascertain identities to preserve public confidence in official documents.

ISSUE

Whether the penalty of a three-month suspension without pay imposed by the Secretary of Justice is appropriate for respondent’s neglect of duty in administering a jurat without verifying the affiants’ identities.

RULING

The Supreme Court set aside the decision of the Secretary of Justice and reinstated the CIR’s penalty of reprimand. The legal logic rests on three key points. First, on jurisdictional hierarchy, Presidential Decree No. 6 and related circulars provided that a decision by a bureau or office head (here, the CIR Acting Presiding Judge) imposing a penalty of suspension for not more than thirty days is final. The Secretary of Justice’s authority to review was limited to penalties “higher” than that threshold. Since the CIR’s original penalty was merely a reprimand—a penalty lower than a 30-day suspension—the Secretary of Justice technically had appellate jurisdiction. However, the Supreme Court, exercising its constitutional power of supervision over all courts, reviewed the propriety of the increased penalty.
Second, on the substantive assessment of the offense, the Court agreed with the CIR’s factual finding that the respondent acted in good faith but with negligence. He was deceived by a familiar party and failed to employ standard verification procedures. The act constituted simple neglect, not the deliberate falsification originally charged.
Third, on the appropriate penalty, the Court applied the doctrine of stare decisis, citing three prior administrative cases (Ramirez v. Ner, Lopez v. Casaclang, Samonte v. Rodrigo, Jr.) where court personnel committed similar omissions in notarizing documents without proper identification. In all those precedents, the Supreme Court imposed only a reprimand and a warning. To ensure uniformity in disciplinary measures and considering the presence of good faith, the lesser penalty was deemed sufficient. The Court emphasized that the primary goal was corrective, not purely punitive, for this type of negligent conduct.