The Supreme Court affirmed the dismissal of Eugenio Sto. Tomas, a Clerk of Court, for dishonesty, grave misconduct, and gross neglect of duty due to misappropriation of judiciary funds and manipulation of court records. The Court emphasized that public servants, especially those handling public funds, must maintain the highest standards of integrity and accountability. This ruling underscores the judiciary’s commitment to maintaining public trust and ensuring that those who betray it are held responsible.

Breach of Trust: How a Clerk’s Betrayal Led to Dismissal and a Judge’s Reprimand

This consolidated case involves multiple administrative charges against Eugenio Sto. Tomas, Clerk of Court of the Municipal Trial Court (MTC) of Cabuyao, Laguna, and Judge Zenaida L. Galvez, the Presiding Judge. The issues stemmed from a 2001 administrative matter concerning the withholding of emoluments of several clerks of court for failure to submit monthly collection reports. This initial inquiry led to a full-blown investigation, revealing serious irregularities in the handling of court funds and records at the Cabuyao MTC, ultimately resulting in administrative sanctions for both Sto. Tomas and Judge Galvez. The Supreme Court meticulously reviewed the findings of the Office of the Court Administrator (OCA) and the investigating judge, focusing on the extent of each respondent’s culpability in the discovered malfeasance.

The investigation revealed a systemic failure in the management of court finances and records under Sto. Tomas’s watch. As Clerk of Court, he was responsible for managing and documenting cash collections allocated for various court funds. The audit teams uncovered significant shortages in remittances, manipulations of ledger entries, mixing of receipts, loss of official receipt booklets, and unauthorized issuance of provisional receipts. The Court found that Sto. Tomas had been misappropriating funds for his personal use since 1985, long before Judge Galvez’s appointment. This misconduct demonstrated a severe breach of integrity and a disregard for the duty of every judiciary employee to uphold the Court’s orders and processes without delay. His actions proved him to be untrustworthy in every aspect of his responsibility.

The Supreme Court highlighted the vital role of Clerks of Court in the administration of justice, quoting Re: Report on the Financial Audit Conducted at the Municipal Trial Court, Baliuag, Bulacan:

Clerks of Court perform a delicate function as designated custodians of the court’s funds, revenues, records, properties, and premises. As such, they are generally regarded as treasurer, accountant, guard, and physical plant manager thereof. It is the duty of the Clerks of Court to faithfully perform their duties and responsibilities. They are the chief administrative officers of their respective courts. It is also their duty to ensure that the proper procedures are followed in the collection of cash bonds. Clerks of Court are officers of the law who perform vital functions in the prompt and sound administration of justice.

The Court emphasized that Clerks of Court must deposit funds immediately into authorized government depositories and cannot keep funds in their custody. The Court pointed to OCA Circular Nos. 50-95 and 113-2004, and Administrative Circular No. 35-2004, which mandate the timely deposit of judiciary collections and the submission of monthly financial reports. Similarly, Administrative Circular No. 3-2000 and SC Circulars No. 13-92 and No. 5-93 demand the immediate deposit of all fiduciary collections in authorized government depository banks, such as the Land Bank of the Philippines. These circulars are non-negotiable and require strict adherence to promote full accountability for government funds.

Sto. Tomas attempted to shift blame to Judge Galvez, alleging that she used the funds for personal expenses. However, the audit reports showed that the mismanagement and embezzlement predated her appointment. His failure to submit financial reports, despite repeated directives, was a deliberate attempt to conceal his wrongdoings. The Court rejected his attempt to evade liability, emphasizing that his grave misdemeanors justified his dismissal from service. The evidence presented confirmed that the anomalies occurred even before Judge Galvez assumed her position, demonstrating a pattern of misconduct and disregard for financial regulations by Sto. Tomas.

In contrast, Judge Galvez was found liable for undue delay in rendering decisions or orders, based on the audit team’s findings of inaction on numerous cases. While she did not request extensions or provide credible explanations for the delays, the Court also noted that the financial irregularities did not occur in other MTCs where she served concurrently. Given her resignation in 2001, the Court deemed a fine of P20,000.00 as an appropriate sanction. Judge Galvez’s failure to address the backlog of cases within a reasonable timeframe was considered a lapse in her administrative duties, warranting disciplinary action.

The administrative actions against Teñido and Manlegro were closed and terminated due to their compliance with the Court’s resolution of paying the fine of P1,000.00 each. The Court ordered the release of their withheld salaries and allowances since they have fully complied with the directives of the Court contained in the Resolution dated May 3, 2005. This demonstrated that compliance with court orders, even after initial delays, could lead to a resolution of administrative liabilities.

The Supreme Court reiterated that dishonesty has no place in the judiciary, emphasizing that malversation of public funds would not be tolerated. The Court has consistently warned that all judiciary personnel must conduct themselves with propriety and decorum, remaining above suspicion at all times. The ruling underscores the importance of upholding public accountability and maintaining faith in the justice system. Because of the respondent’s transgressions and numerous violations of the Court’s administrative circulars, the 2002 Revised Manual for Clerks of Courts and the Code of Conduct for Court Personnel, the Court was left with no other recourse but to recommend his dismissal from the service, pursuant to Section 52, A(1)(3), Rule IV of the Revised Uniform Rules on Administrative Cases in the Civil Service.

FAQs

What was the key issue in this case?	The key issue was whether Eugenio Sto. Tomas and Judge Zenaida L. Galvez should be held administratively liable for irregularities in the Municipal Trial Court of Cabuyao, Laguna. The core of the matter involved allegations of dishonesty, misconduct, and neglect of duty.
What specific actions led to the dismissal of Eugenio Sto. Tomas?	Sto. Tomas was dismissed for serious dishonesty, grave misconduct, and gross neglect of duty, stemming from the misappropriation of judiciary funds and manipulation of court records. These actions constituted a breach of trust and a violation of his responsibilities as Clerk of Court.
What was the basis for the Court’s decision regarding Sto. Tomas’s actions?	The Court relied on audit reports that revealed shortages in remittances, manipulated ledger entries, loss of official receipts, and unauthorized issuance of provisional receipts. These findings indicated a pattern of financial irregularities and dishonesty.
Why was Judge Galvez found administratively liable, and what was her punishment?	Judge Galvez was found liable for undue delay in rendering decisions or orders due to inaction on numerous cases. Considering her prior resignation, the Court imposed a fine of P20,000.00 to be deducted from her accrued leave credits.
What circulars and regulations did Sto. Tomas violate?	Sto. Tomas violated OCA Circular Nos. 50-95 and 113-2004, Administrative Circular No. 35-2004, Administrative Circular No. 3-2000, and SC Circulars No. 13-92 and No. 5-93, which mandate the proper handling and deposit of court funds. These violations demonstrated a clear disregard for established financial procedures.
What was Sto. Tomas’s defense, and why was it rejected?	Sto. Tomas attempted to blame Judge Galvez for the misappropriation of funds, but the Court rejected this defense. The audit reports revealed that his misconduct predated her appointment, indicating that he was the primary culprit.
What happened to the administrative cases against Teñido and Manlegro?	The administrative cases against Teñido and Manlegro were closed and terminated. They paid the fine of P1,000.00 each, and the Court ordered the release of their withheld salaries and allowances.
What is the significance of this ruling for public servants?	This ruling reinforces the principle that public servants, especially those handling funds, must maintain the highest standards of integrity and accountability. Dishonesty will not be tolerated and will result in severe consequences.

This case serves as a reminder of the judiciary’s commitment to weeding out corruption and upholding the integrity of the justice system. The Court’s firm stance against dishonesty and neglect of duty sends a clear message to all court personnel: accountability is paramount, and breaches of public trust will be met with appropriate sanctions.

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: EUGENIO STO. TOMAS VS. JUDGE ZENAIDA L. GALVEZ, A.M. No. MTJ-01-1385, March 19, 2019