GR 234260; (July, 2020) (Digest)
G.R. No. 234260 . July 01, 2020
TEODORO C. LINSANGAN, PETITIONER, VS. OFFICE OF THE OMBUDSMAN AND LEONARDO O. ORIG, RESPONDENTS.
FACTS
Petitioner Teodoro C. Linsangan was the Registrar of Deeds of Cabanatuan City. On July 31, 2008, respondent Leonardo O. Orig and his sister-in-law went to the Registry to verify the existence of three Original Certificates of Title (OCTs) and one Transfer Certificate of Title (TCT). They were later issued a Certification, signed by petitioner, verified by Vault Keeper Emilio De Guzman, and checked by Officer-in-Charge Marlon B. Romero, stating that the titles could not be located and were recorded as severely mutilated per a 1982 inventory. Orig, unconvinced, later found machine copies of some of the titles in the Registry’s files and claimed the Certification was false. In his defense, petitioner argued he assumed office in 1986, after the 1982 inventory, and that he relied in good faith on his subordinates who had primary responsibility for verification. The Office of the Ombudsman found petitioner guilty of Gross Neglect of Duty and imposed the penalty of dismissal, which was affirmed by the Court of Appeals.
ISSUE
Whether petitioner Teodoro C. Linsangan is guilty of Gross Neglect of Duty for issuing a Certification containing erroneous information based on his reliance on the verification of his subordinates.
RULING
No. The Supreme Court granted the petition and reversed the rulings of the Court of Appeals and the Ombudsman. Applying the doctrine in Arias v. Sandiganbayan, the Court held that heads of offices, like petitioner, may rely to a reasonable extent on their subordinates and on the good faith of those who prepare documents. There was no showing that petitioner was motivated by malice or gross negligence amounting to bad faith. His mere signature on the Certification, without more, does not automatically make him liable. The Court emphasized that not every mistake by a public officer is actionable absent a clear showing of malice or gross negligence amounting to bad faith.