G.R. No. A.M. No. P-16-3550. January 31, 2017. JUDGE GUILLERMO P. AGLORO, Complainant, vs. COURT INTERPRETER LESLIE J. BURGOS, OFFICER-IN-CHARGE/CLERK III ANNALIZA P. SANTIAGO, COURT STENOGRAPHER MARISSA M. GARCIA, and CLERK III JULIETA FAJARDO, all of Regional Trial Court, Branch 83, Malolos City, Bulacan, Respondents.
FACTS

This administrative case originated from an oral report by Presiding Judge Guillermo P. Agloro of RTC, Branch 83, Malolos City, concerning irregularities in LRC Case No. P-335-2011, a petition for reconstitution of titles. Judge Agloro reported that the case was raffled to Branch 77 but inexplicably appeared in Branch 83, which then heard and granted the petition. The Office of the Clerk of Court later refused to register the entry of judgment because the case belonged to Branch 77, creating a predicament for Judge Agloro regarding a pending motion for execution.
An investigation by Executive Judge Ma. Theresa V. Mendoza-Arcega confirmed the irregularities. The case was legitimately raffled to Branch 77, with a fully signed raffle sheet in its records. In contrast, the case folder in Branch 83 lacked a fees assessment form and contained a raffle sheet with only three signatures, which were later determined to be forgeries. The investigation revealed that respondents Annaliza P. Santiago and Marissa M. Garcia were primarily involved in the anomalous transfer and processing of the case in Branch 83.

ISSUE

Whether respondents are administratively liable for their actions concerning the irregular handling and adjudication of LRC Case No. P-335-2011.

RULING

Yes, but liability varies per respondent. The Court dismissed the complaints against Leslie J. Burgos and Julieta Fajardo for lack of merit, as their involvement was limited to reporting the anomaly. However, respondents Marissa M. Garcia and Annaliza P. Santiago were found GUILTY of Grave Misconduct, Dishonesty, and Conduct Prejudicial to the Best Interest of the Service.
The legal logic is grounded in the grave nature of their acts, which undermined judicial integrity. Garcia and Santiago facilitated the unauthorized transfer of the case to Branch 83 using a forged raffle sheet, actively participated in its proceedings, and attempted to register a fraudulent entry of judgment. These acts constitute a deliberate scheme to circumvent the raffle system, a fundamental procedural safeguard ensuring impartial case assignment. Such behavior constitutes Grave Misconduct, characterized by a wrongful intent to violate established rules. It also constitutes Dishonesty through the use of forged documents and deceitful conduct. Collectively, these actions are Prejudicial to the Best Interest of the Service, as they erode public trust in the judiciary’s fairness and regularity. For these grave offenses, the penalty of dismissal from service is imposed, carrying forfeiture of benefits and perpetual disqualification from re-employment in government, as mandated by the Revised Rules on Administrative Cases in the Civil Service.