The Supreme Court’s decision in Office of the Court Administrator v. Sidro underscores the judiciary’s commitment to maintaining the integrity of court processes. This case involved court personnel who colluded to antedate affidavits, thereby falsifying the official record. The Court found Sheriff Teodoro G. Sidro guilty of grave misconduct for instigating the act, leading to his dismissal. Sheriff Rolly S. Ocampo was suspended for simple misconduct and conduct prejudicial to the best interest of service, while Clerk Leonelle E. Mendoza was fined for simple negligence. This ruling serves as a stern warning to all court employees that any act of dishonesty or negligence will be met with severe consequences.

The Ticking Clock: When Backdating Documents Undermines Justice

This case originated from a complaint filed by Mr. Andrew Ang, an officer of Kelam Realty Corporation, alleging that certain court personnel conspired to antedate the receipt of affidavits in Civil Case No. 30898. Ang accused Clerk of Court Maria Theresa C. Gonzales and other staff members of Branch 53 of the Metropolitan Trial Court (MeTC) of Caloocan City of making it appear that Kelam Realty Corporation had filed the affidavits on time. The affidavits were stamped “received” on March 16, 2015, but were actually executed and notarized on March 17, 2015. Judge Dante R. Corminal directed his staff to submit comments, leading to a fact-finding investigation which ultimately reached the Office of the Court Administrator (OCA).

The investigation revealed that Sheriff Sidro instructed Clerk Mendoza to stamp the affidavits with the earlier date, assuring him that Gonzales was informed. Sheriff Ocampo allegedly handed the affidavit to Mendoza and even adjusted the date on the dater. Another clerk, Ronsairo, corroborated this, stating that Sidro and Ocampo had initially approached her to antedate the documents. While Ocampo admitted to being present during the incident, Sidro denied any liability, blaming Ocampo. The OCA recommended sanctions against Sidro, Ocampo, and Mendoza, while recommending dismissal of the complaint against Gonzales. The Supreme Court largely adopted the OCA’s recommendations but modified the finding against Ocampo.

The Court anchored its decision on the definitions of misconduct and conduct prejudicial to the best interest of the service. According to jurisprudence, misconduct is any unlawful conduct that prejudices the rights of parties or the administration of justice. The Court has consistently held that misconduct should relate directly to the performance of official duties. Conduct prejudicial to the best interest of the service, on the other hand, is any act that violates public accountability or diminishes public faith in the judiciary.

The act of antedating court documents was deemed a clear instance of misconduct. Rule 13, Section 3 of the Rules of Court mandates that the date of actual receipt is the basis for determining the timeliness of filing pleadings. Antedating, therefore, is a deliberate act of dishonesty that undermines the integrity of the filing process and ultimately affects the resolution of cases. Moreover, the Court emphasized that antedating constitutes making false entries in public documents, an act that falls under conduct prejudicial to the best interest of the service. Such actions tarnish the image and integrity of the judiciary, eroding public trust.

In assessing the culpability of each respondent, the Court relied on the standard of substantial evidence. This standard requires a reasonable ground to believe that a person is responsible for the misconduct, even if the evidence is not overwhelming. Here, the corroborating statements of Mendoza, Ronsairo, and Ocampo pointed to Sidro as the instigator. His defense of bare denial was insufficient to outweigh the positive testimonies against him. The Court noted Sidro’s intent to disregard established rules when he instructed Mendoza to antedate the documents and falsely claimed that Gonzales had approved the action.

“wag na, alam na ni Boss yan,” Sidro said to Mendoza. This statement showcases how serious it is to disregard the truth. The Court emphasized that antedating documents violates the public’s trust in the justice system. This is why the Court decided to dismiss Sidro from his position. His actions were a grave offense against the principles of fairness and honesty that every court employee should uphold.

The Court found Ocampo also guilty of misconduct and conduct prejudicial to the interest of the service. The Court rejected his claim that he was unaware of the significance of his actions, given his prior experience as a security guard at the Supreme Court. This experience should have provided him with a basic understanding of court processes, making his participation in the antedating incident inexcusable. The court determined that Ocampo’s actions, though not involving corruption or willful intent, still constituted simple misconduct and conduct prejudicial to the best interest of the service, resulting in a one-year suspension.

Mendoza’s defense of good faith was also rejected. While the Court acknowledged his relative inexperience, it noted that he had been informed of his duties and responsibilities as Clerk III. His own hesitation before antedating the documents indicated that he was aware of the irregularity. However, due to the absence of evidence showing premeditation or intentional wrongdoing, the Court found him guilty only of simple negligence and imposed a fine equivalent to one month’s salary.

The Court in this case, referenced past administrative cases that demonstrate how serious it is to violate the code of conduct. The Court quoted Section 46, Rule 10 of the Revised Rules on Administrative Cases in the Civil Service, Civil Service Commission (CSC) Resolution No. 1101502, November 8, 2011 for the penalties. The penalty for Sidro was dismissal from service because what he did was very serious. Also the Court did not take it easy on the others and the Supreme Court also quoted other cases that discussed simple neglect of duty.

FAQs

What was the key issue in this case?	The key issue was whether court personnel should be held administratively liable for antedating affidavits, thereby falsifying the official record.
What is the definition of misconduct according to the Supreme Court?	Misconduct is defined as any unlawful conduct that prejudices the rights of parties or the administration of justice, relating directly to the performance of official duties.
What is considered “conduct prejudicial to the best interest of the service”?	This refers to any act that violates public accountability or diminishes the public’s faith in the judiciary.
What standard of evidence did the Court use to determine the respondents’ guilt?	The Court applied the standard of substantial evidence, requiring a reasonable ground to believe that the person is responsible for the misconduct.
What was Sheriff Sidro’s role in the antedating incident?	Sheriff Sidro was found to have instigated the antedating of the affidavits, instructing Clerk Mendoza to stamp the documents with an earlier date.
Why was Sheriff Ocampo also found liable?	Sheriff Ocampo was found liable because he handed the affidavit to Mendoza, adjusted the date on the dater, and failed to challenge Sidro’s instructions, despite his prior experience with court processes.
What was the basis for Clerk Mendoza’s liability?	Clerk Mendoza was held liable for simple negligence because he antedated the documents without verifying with the Clerk of Court, despite his own hesitation about the irregularity of the act.
What were the penalties imposed on the respondents?	Sheriff Sidro was dismissed from service, Sheriff Ocampo was suspended for one year, and Clerk Mendoza was fined an amount equivalent to one month’s salary.
What is the significance of antedating court documents?	Antedating court documents is a deliberate act of dishonesty that undermines the integrity of the filing process and erodes public trust in the judiciary.

The Supreme Court’s ruling in this case reinforces the importance of integrity and accountability within the judiciary. By imposing sanctions on those involved in the antedating incident, the Court sends a clear message that any act of dishonesty or negligence will not be tolerated. This decision serves as a reminder to all court personnel of their duty to uphold the highest standards of ethical conduct and maintain public trust in the administration of justice.

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: OFFICE OF THE COURT ADMINISTRATOR VS. TEODORO G. SIDRO, ET AL., A.M. No. P-17-3655, August 20, 2019