G.R. No. 150091 . April 2, 2007.
YOLANDA O. ALFONSO, Petitioner, vs. OFFICE OF THE PRESIDENT and PHIL-VILLE DEVELOPMENT AND HOUSING CORPORATION, Respondents.

FACTS

Petitioner Yolanda O. Alfonso, the Register of Deeds of Caloocan City, was dismissed for grave misconduct and dishonesty. The charges stemmed from her issuance of three Transfer Certificates of Title (TCTs) in 1996 in the name of Eleuteria Rivera, derived from Original Certificate of Title (OCT) No. 994. These TCTs stated OCT No. 994 was registered on April 19, 1917. Private respondent Phil-Ville, which held derivative TCTs stating the registration date as May 3, 1917, complained. A Senate committee report concluded there was only one OCT No. 994, registered on May 3, 1917, and that an April 19, 1917 date was a fabrication. The report found petitioner acted maliciously in signing the Rivera TCTs with the wrong date, allegedly acquiescing to a change in the registration date and creating two versions of OCT No. 994.
The administrative case proceeded, with the Office of the President affirming petitioner’s dismissal. The Court of Appeals sustained this decision. Petitioner elevated the case, arguing she merely complied with a final and executory court order from the Regional Trial Court (RTC) of Caloocan City, Branch 120, which directed the issuance of new titles for Rivera. She asserted she relied on the technical descriptions provided by the court and the administrative support of her subordinates, who prepared the titles based on available records.

ISSUE

Whether petitioner is administratively liable for grave misconduct and dishonesty in issuing the TCTs with the April 19, 1917 date for OCT No. 994.

RULING

No. The Supreme Court reversed the findings of administrative liability. The Court emphasized that in administrative cases, the burden of proof lies with the complainant, and the evidence must be substantial. Here, the Senate committee report, being hearsay, lacked probative value as it was not subject to cross-examination. The core of the charge was that petitioner deliberately used a false date. However, the evidence showed she acted pursuant to a specific and direct Order dated September 9, 1996, from Judge Jaime D. Discaya, which had become final and executory. As a ministerial officer, she had a duty to comply.
The Court found no proof of wrongful intent or conscious design to commit fraud. Her act of signing the titles was a routine discharge of duty based on the court order and the supporting documents prepared by her staff. There was no showing she had personal knowledge of any alleged fabrication or that she conspired to create a false title. Mere negligence, if any, in relying on her subordinates’ work does not equate to the deliberate wrongdoing required for grave misconduct or dishonesty. Absent clear evidence of malicious intent, the presumption of regularity in the performance of official duty stands. Thus, the dismissal was not justified.