AM R 459 P; (September, 1986) (Digest)
G.R. No. A.M. No. R-459-P September 15, 1986
THE COURT ADMINISTRATOR, represented by Atty. Romanito Amatong, vs. NUMERIANO GALANG, OIC of the Office of the Clerk of Court and DOLORES OCAMPO, Deputy Clerk of Court, Branch I, CFI Nueva Ecija, Cabanatuan City.
FACTS
This administrative case stemmed from an investigation into irregularities in the recording and handling of docket books at the Court of First Instance in Cabanatuan City. Respondents Atty. Numeriano Galang, then Officer-in-Charge of the Office of the Clerk of Court, and Mrs. Dolores Ocampo, Deputy Clerk of Court, were required to show cause why disciplinary action should not be taken against them for failures to make proper entries in the criminal and civil docket books as mandated by Section 8, Rule 136 of the Rules of Court. In their explanations, Galang admitted certain lapses but cited the standard practice of delegating entry tasks to clerks under the supervision of individual judges. Ocampo, who assumed her deputy role in 1980, claimed a lack of awareness of separate docket procedures, noting the court’s practice of centralized records management.
The case was referred for investigation to Executive Judge Quirino Sadang. His report confirmed that while criminal docket entries had been updated, the civil docket book contained numerous blank pages interspersed among the entries from pages 1 to 481. Court personnel explained that pages were left blank when one page was insufficient for a case’s entries, a practice the investigating judge admonished. The report noted that records had since been updated in compliance with the rules.
ISSUE
Whether respondents Atty. Numeriano Galang and Mrs. Dolores Ocampo should be held administratively liable for the irregularities in the court’s docket books.
RULING
The Court absolved both respondents from administrative liability but issued a warning to Atty. Galang. The legal logic centered on the absence of deliberate intent to violate the rules and the presence of mitigating circumstances. The Court found that the respondents’ failure to make proper entries was not willful but was hampered by a lack of essential supplies, such as sufficient docket books, and by established but incorrect office practices. The investigation confirmed that the records had subsequently been corrected and brought into compliance with Rule 136.
The resolution emphasized that while negligence was present, the absence of bad faith and the subsequent remedial actions warranted leniency. However, the Court used the occasion to reiterate the critical importance of strict adherence to docketing rules to ensure the integrity of court records and accurate case tracking. A directive was issued to the Office of the Court Administrator to ensure lower courts are properly supplied with necessary docket books to prevent similar lapses. The warning to Galang, who remained in service as Clerk of Court, served as a reminder of his supervisory duties and the stricter consequences for any future negligence.