In Atty. Rhea R. Alcantara-Aquino v. Mylene H. Dela Cruz, the Supreme Court addressed the severe consequences of a court employee’s misconduct involving the falsification of court documents. The Court found Mylene H. Dela Cruz, a Clerk III, guilty of gross misconduct and dishonesty for authenticating spurious court documents. Despite her resignation, the Supreme Court imposed a fine of P40,000.00, forfeiture of retirement benefits (except accrued leave credits), and disqualification from re-employment in any government branch. This decision underscores the judiciary’s zero-tolerance policy towards acts that undermine the integrity of court documents and public trust.

Forged Finality: When Court Employees Betray the Public Trust

The case revolves around Mylene H. Dela Cruz, a Clerk III at the Regional Trial Court (RTC) in Santa Cruz, Laguna, who was accused of authenticating falsified court documents. Atty. Rhea R. Alcantara-Aquino, Assistant Clerk of Court, filed the complaint after discovering irregularities in a petition for correction of entry in a marriage contract. The documents, including a purported court order and a certificate of finality, were found to be spurious, with forged signatures. This discovery led to an investigation that implicated Dela Cruz in a scheme involving the falsification of public documents.

The issue began when Mrs. Emerita B. Moises, the Municipal Civil Registrar of Nagcarlan, Laguna, sought to verify the legitimacy of documents presented in SP. Proc. Case No. SC-2268, a Petition for Correction of Entry in the Marriage Contract. The documents included an Order dated May 4, 2007, supposedly issued by Judge Jaime C. Blancaflor and certified by Atty. Aquino. However, upon verification, Atty. Aquino discovered that no such case existed under that number, and the documents were forgeries.

Further investigation revealed that the signatures of both Atty. Aquino and Judge Blancaflor were forged, and the rubber stamp used to certify the documents was different from the court’s official stamp. Ms. Igamen, the alleged petitioner in the case, identified Dela Cruz as the person who assisted her after being referred by Mr. Laudemer F. San Juan, the Municipal Civil Registrar of Santa Cruz, Laguna. Dela Cruz admitted to certifying copies of the spurious order at San Juan’s request, even issuing a handwritten note stating, “Na wala akong kinalaman sa lahat nang naging conflict sa petition ni Bella Igamen dahil pinakiusapan lang ako ni Mr. Laudemer San Juan.”

Despite knowing the documents were fraudulent, Dela Cruz authenticated them, leading to the anomalous annotation of the spurious order in Ms. Igamen’s marriage certificate. This act prompted Atty. Aquino to file a complaint with the National Bureau of Investigation (NBI) and request Judge Blancaflor to issue a memorandum to local civil registries to prevent similar occurrences. The NBI’s investigation led to the filing of charges for Estafa thru Falsification of Public Documents against Dela Cruz, San Juan, and Ms. Apolonia B. Gamara.

The Supreme Court emphasized the high ethical standards required of judiciary employees, stating that they must be examples of integrity, uprightness, and honesty. The Court cited Republic Act 6713, the Code of Conduct and Ethical Standards for Public Officials and Employees, which promotes a high standard of ethics and responsibility in public service. The court said:

Every employee of the judiciary should be an example of integrity, uprightness and honesty. The Supreme Court has repeatedly emphasized that the conduct of court personnel, from the presiding judge to the lowliest clerk, must always be beyond reproach and must be circumscribed with the heavy burden of responsibility as to let them be free from any suspicion that may taint the judiciary. The Court condemns and would never countenance any conduct, act or omission on the part of all those involved in the administration of justice which would violate the norm of public accountability and diminish or even just tend to diminish the faith of the people in the judiciary.

The Court found Dela Cruz’s actions to be a clear violation of these standards. She knew the documents were spurious, she was not authorized to authenticate documents, and she refused to address the charges against her. The court noted that:

(1) Dela Cruz knew that there were no existing records that could have served as the basis for the issuance of the disputed certificate; (2) authenticating documents was neither part of Dela Cruz’s duties nor was she authorized to authenticate documents; (3) Dela Cruz, despite knowledge that she was not authorized to authenticate, admitted having authenticated the questioned order and issued the certificate of finality in SP Proc. Case No. SC-2268 allegedly upon the request of Municipal Civil Registrar San Juan; and (4) Dela Cruz refused to face the charges against her, in disregard of the Court’s directives.

The Supreme Court highlighted the significance of certifications, explaining that: “A certificate is a written assurance, or official representation, that some act has or has not been done, or some event occurred, or some legal formality has been complied with. To certify is to attest the truthfulness of the document. Without the records to verify the truthfulness and authenticity of a document, no certification should be issued. This is basic.” Dela Cruz, by certifying a non-existent court order, compromised the Judiciary and jeopardized the integrity of the court. Her actions demonstrated complicity in irregular and unethical practices.

Given the gravity of the offense, the Supreme Court imposed the penalty of a fine of P40,000.00, forfeiture of retirement benefits (except accrued leave credits), and perpetual disqualification for re-employment in the government service, despite her prior resignation. The Court also ordered the Provincial Prosecutor of Laguna to report on the status of the criminal case against Dela Cruz and requested the Municipal Mayor of Santa Cruz, Laguna, to investigate Laudemer F. San Juan and other employees who may have participated in the illegal scheme.

FAQs

What was the key issue in this case?	The key issue was whether a court employee could be held administratively liable for authenticating falsified court documents, even after resigning from their position.
What was Mylene H. Dela Cruz’s role in the falsification?	Mylene H. Dela Cruz, as a Clerk III, authenticated spurious court documents, including a court order and certificate of finality, despite knowing they were not genuine.
What penalty did the Supreme Court impose on Dela Cruz?	The Supreme Court imposed a fine of P40,000.00, forfeiture of retirement benefits (except accrued leave credits), and disqualification from re-employment in any government branch, despite her resignation.
Why was Dela Cruz penalized despite her resignation?	The Supreme Court emphasized that resignation does not preclude administrative liability for misconduct committed during employment.
What ethical standards are expected of judiciary employees?	Judiciary employees are expected to uphold the highest standards of integrity, uprightness, and honesty, and their conduct must be beyond reproach.
What is the significance of a certificate issued by a court employee?	A certificate is an official representation that an act has been done or an event has occurred, attesting to the truthfulness of the document under the court’s seal.
What was the basis for the charges against Dela Cruz?	The charges were based on Dela Cruz’s admission of authenticating the documents, the NBI’s investigation, and the discovery of forged signatures and a non-existent case number.
What was the role of Laudemer F. San Juan in this case?	Laudemer F. San Juan, the Municipal Civil Registrar of Santa Cruz, Laguna, requested Dela Cruz to authenticate the spurious documents and was also implicated in the falsification scheme.

This case serves as a stern reminder to all public servants, especially those in the judiciary, of the importance of maintaining the highest ethical standards and upholding the integrity of public documents. The Supreme Court’s decision underscores the severe consequences that can arise from betraying public trust and engaging in fraudulent activities.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: ATTY. RHEA R. ALCANTARA-AQUINO VS. MYLENE H. DELA CRUZ, A.M. No. P-13-3141, January 21, 2014