The Supreme Court, in Garingan-Ferreras v. Umblas, underscores the stringent standards of conduct expected from public servants, particularly those in the judiciary. The Court affirmed the finding that Eduardo T. Umblas, a Legal Researcher II, was guilty of falsifying a Certificate of Finality, a grave offense that undermines the integrity of court processes. This decision reinforces that public officials must maintain the highest level of honesty and ethical behavior, as their actions directly impact public trust and the administration of justice.

Forged Finality: Can a Court Employee Be Penalized for a False Document in a Non-Existent Case?

Wyna Marie G. Ferreras filed a complaint against Eduardo T. Umblas, a Legal Researcher II at the Regional Trial Court (RTC), Branch 33, Ballesteros, Cagayan, alleging falsification of public documents. The core of the complaint stemmed from a Certificate of Finality, purportedly issued by the RTC, declaring her marriage to Reynaldo Z. Ferreras null and void. This document was critical because it led to an annotation on her marriage records with the National Statistics Office (NSO). However, Ferreras claimed she had no knowledge of such a case and that no such case existed. A certification from the RTC confirmed that Civil Case No. 33-398C-2006, the purported case number in the Certificate of Finality, was not on file. Umblas denied the allegations, claiming the signature on the certificate was not his and that the document was fraudulent. This prompted an investigation to ascertain the veracity of the claims and to determine if Umblas had indeed falsified an official document.

The Investigating Judge, Vilma T. Pauig, found Umblas guilty of falsification, noting that his signature on the Certificate of Finality closely resembled his signature on the Comment he submitted during the investigation. This comparison led to the inference that Umblas was indeed the author of the falsified document. The Investigating Judge stated:

Contrary to the respondent’s vehement denial of his participation in the annulment of the petitioner’s marriage, the evidence on record substantially proves that his signature in the Certificate of Finality bears a striking resemblance to the signature he uses when compared to his signature in the Comment he submitted dated February 18, 2013. x x x

Furthermore, Umblas failed to present any evidence to support his claim that his signature was forged. As the party alleging forgery, the burden of proof rested on him to provide clear and convincing evidence, which he failed to do. The Investigating Judge recommended his dismissal from service, a penalty commensurate with the gravity of the offense.

The Office of the Court Administrator (OCA) concurred with the Investigating Judge’s findings, emphasizing that Ferreras had provided substantial evidence of fraud against Umblas. The OCA highlighted the certified true copies of the Decision and Certificate of Finality obtained from the NSO, which were the basis for the annotation on Ferreras’ marriage contract. These documents, coupled with Umblas’ failure to attend the hearings and controvert the authenticity of his signature, led the OCA to conclude that he was indeed responsible for the falsified Certificate of Finality.

The Supreme Court adopted the findings of the Investigating Judge and the OCA, holding Umblas accountable for his actions. The Court emphasized that when forgery is alleged, the burden of proof lies with the party making the allegation. In this case, Umblas failed to provide any credible evidence to support his claim that his signature was forged. The Court cited Section 22, Rule 132, Rules of Court, which allows for the comparison of handwriting to determine its genuineness.

The Supreme Court held in Dabu v. Judge Kapunan, 656 Phil. 230, 242 (2011):

The rule is that he who disavows the authenticity of his signature on a public document bears the responsibility of presenting evidence to that effect. Mere disclaimer is not sufficient. x x x At the very least, he should present corroborating evidence to prove his assertion. At best, he should present an expert witness. As a rule, forgery cannot be presumed and must be proved by clear, positive and convincing evidence and the burden of proof lies on the party alleging forgery.

Umblas’ failure to attend hearings and his overall lack of diligence in defending himself further strengthened the Court’s conviction that he was guilty of falsification. The Court emphasized the high standards of conduct expected from court employees, stating that they should be models of uprightness, fairness, and honesty. The court held that:

Court employees, from the presiding judge to the lowliest clerk, being public servants in an office dispensing justice, should always act with a high degree of professionalism and responsibility. Their conduct must not only be characterized by propriety and decorum, but must also be in accordance with the law and court regulations. No position demands greater moral righteousness and uprightness from its holder than an office in the judiciary. Court employees should be models of uprightness, fairness and honesty to maintain the people’s respect and faith in the judiciary. They should avoid any act or conduct that would diminish public trust and confidence in the courts. Indeed, those connected with dispensing justice bear a heavy burden of responsibility.

Initially, the gravity of Umblas’ offense would have warranted dismissal from service. However, the Court noted that Umblas had already been dismissed in a previous case, Office of the Court Administrator v. Umblas, A.M. No. P-09-2621, September 20, 2016, for similar misconduct. Therefore, the Court imposed a fine of P40,000.00 to be deducted from his accrued leave credits, recognizing that the penalty of dismissal was no longer feasible. The Court also directed the Office of the Court Administrator to file appropriate criminal charges against Umblas.

FAQs

What was the central issue in this case?	The central issue was whether Eduardo T. Umblas fraudulently prepared and signed a Certificate of Finality for a non-existent case, leading to the nullification of Wyna Marie G. Ferreras’ marriage and its annotation with the NSO.
What was the basis for the finding of guilt against Umblas?	The finding of guilt was based on the striking resemblance between Umblas’ signature on the falsified Certificate of Finality and his known signatures, his failure to disprove the forgery, and his lack of diligence in defending himself during the investigation.
What is the standard of conduct expected of court employees?	Court employees are expected to act with a high degree of professionalism, responsibility, and integrity. Their conduct must be in accordance with the law and court regulations to maintain public trust and confidence in the judiciary.
What happens when a party alleges forgery in a legal document?	The party alleging forgery bears the burden of proving it with clear, positive, and convincing evidence. Mere denial is insufficient; corroborating evidence, including expert testimony, may be required.
What penalty was initially warranted for Umblas’ offense?	The initial penalty warranted was dismissal from service, given that falsification of an official document is a grave offense under the Revised Rules on Administrative Cases in the Civil Service (RRACCS).
Why was the penalty of dismissal not imposed in this case?	The penalty of dismissal was not imposed because Umblas had already been dismissed from service in a previous case for similar misconduct.
What was the actual penalty imposed on Umblas?	In lieu of dismissal, Umblas was ordered to pay a fine of P40,000.00, to be deducted from his accrued leave credits.
What action was the Office of the Court Administrator directed to take?	The Office of the Court Administrator was directed to file appropriate criminal charges against Umblas.

The Supreme Court’s decision in Garingan-Ferreras v. Umblas serves as a reminder that public servants must uphold the highest standards of integrity and ethical conduct. The falsification of official documents not only undermines the judicial process but also erodes public trust in the government. This case reinforces the principle that those who betray the public’s trust will be held accountable for their actions, ensuring the integrity and credibility of the Philippine justice system.

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: WYNA MARIE P. GARINGAN­-FERRERAS VS. EDUARDO T. UMBLAS, G.R. No. 62734, January 10, 2017