EN BANC
[ A.M. No. MTJ-06-1620 [Formerly A.M. No. 05-11-338-MTCC], January 30, 2009 ]INITIAL REPORT ON FINANCIAL AUDIT CONDUCTED AT OFFICE OF CLERK OF COURT (OCC) +
INITIAL REPORT ON THE FINANCIAL AUDIT CONDUCTED AT THE OFFICE OF THE CLERK OF COURT (OCC), MUNICIPAL TRIAL COURT IN CITIES (MTCC), LUCENA CITY.
D E C I S I O N
INITIAL REPORT ON FINANCIAL AUDIT CONDUCTED AT OFFICE OF CLERK OF COURT (OCC) +
INITIAL REPORT ON THE FINANCIAL AUDIT CONDUCTED AT THE OFFICE OF THE CLERK OF COURT (OCC), MUNICIPAL TRIAL COURT IN CITIES (MTCC), LUCENA CITY.
D E C I S I O N
PER CURIAM:
The Financial Audit Team of the Office of the Court Administrator (OCA) conducted a financial audit at the Office of the Clerk of Court (OCC), Municipal Trial Court in Cities (MTCC), Lucena City on March 11 up to 18, 2005. The audit covered the
accountability period from 1985 up to February 28, 2005 of Gil B. Reynoso (respondent), Clerk of Court IV, OCC, MTCC, Lucena City.
Acting on respondent's Answer[6] which was prepared and signed in California, USA, this Court, on the recommendation of the OCA, required respondent anew to submit the missing documents enumerated in the Resolution of January 18, 2006, except those official receipts which were submitted to the Commission on Audit (COA).[7]
Respondent submitted his Manifestation and Compliance dated March 13, 2006,[8] explaining at length as follows:
The Court Management Office presented respondent's Summary of Accountabilities as of February 28, 2005, with a caveat that the "computed liabilities may change upon submission and examination of the missing documents required [of] him," as follows:
Safekeeping of public and trust funds is essential to an orderly administration of justice. No protestation of good faith can override the mandatory nature of the circulars designed to promote full accountability of government funds.[14] The Court has not hesitated to impose the ultimate penalty on those who have fallen short of their accountabilities. Any conduct that would violate the norms of public accountability and diminish, or even merely tend to diminish, the faith of the people in the justice system has never been tolerated or condoned by the Court.[15] This ought to be so, as no less than the 1987 Constitution dictates:
Compounding respondent's liability is his continued unexplained failure to comply with the directives to submit the missing documents mentioned above, which clearly speaks of his disregard of the duty of every employee of the Judiciary to obey the orders and processes of this Court without delay.[21]
Respondent's restitution of the shortages he incurred does not free him from the consequences of his wrongdoing and erase his administrative culpability.[22]
For his failure then to live up to the high ethical standards expected of court employees, respondent's dismissal is indeed in order.
WHEREFORE, this Court finds respondent, Gil B. Reynoso, GUILTY of gross neglect of duty. He is ordered DISMISSED from the service with forfeiture of all retirement benefits, excluding accrued leave credits, with prejudice to re-employment in any government office, including government-owned and controlled corporations.
For his failure to return the missing documents despite repeated orders of this Court, he is found GUILTY of contempt of court and is ordered to pay a FINE of Five Thousand (P5,000) Pesos and to submit all the required documents to the OCA within thirty days from receipt of this Decision.
The Financial Management Office, Office of the Court Administrator, is DIRECTED to process the terminal leave benefits of respondent with dispatch and apply the same to his accountabilities, giving priority to the Fiduciary Fund Account of MTCC-Lucena City.
Upon submission of the missing documents by respondent, the Financial Management Office, Office of the Court Administrator, is DIRECTED to compute the remaining accountabilities of respondent, if any, and to submit a report thereon within thirty days from compliance of respondent.
Respondent is ordered to RESTITUTE the difference of One Million Nine Hundred Thirty-Three Thousand Four Hundred Five Pesos and Sixty-Nine Centavos (P1,933,405.69) and whatever amount that will be remitted by the Financial Management Office of the Office of the Court Administrator.
The Office of the Court Administrator is DIRECTED to initiate appropriate criminal proceedings against respondent in light of the above findings of the Court.
SO ORDERED.
Quisumbing, (Acting C.J.), Carpio, Austria-Martinez, Corona, Carpio Morales, Tinga, Chico-Nazario, Nachura, Leonardo-De Castro, Brion, and Peralta, JJ. , concur.
Puno, C.J., Ynares-Santiago, Azcuna, and Velasco, Jr., JJ., on official leave.
[1] The total amount is P1,776,642.90.
[2] Rollo, pp. 1-7.
[3] Id. at 87-94.
[4] Id. at 95-103.
[5] By letter of February 28, 2006, Executive Judge Romeo L. Villanueva informed the Court that respondent left for the United States of America on October 21, 2005 and has not yet returned as of the time of writing of the letter. The January 18, 2006 Resolution of the Court and the Hold Departure Order of even date were received by the eldest daughter of respondent on February 4, 2006.
[6] Rollo, pp. 148-154.
[7] Rollo, p. 186.
[8] Id. at 188-198.
[9] Id. at 189-196.
[10] Id. at 197.
[11] Id. at 202.
[12] Id. at 215-217.
[13] Id. at 217-218.
[14] Re: Financial Audit on the Accountabilities of Mr. Restituto A. Tabucon, Jr., Former Clerk of Court II of the MCTC, Ilog, Candoni, Negros Occidental,A.M. No. 04-8-1-195-MCTC, August 18, 2005, 467 SCRA 246, 250.
[15] Angeles A. Velasco v. Atty. Prospero V. Tablizo, A.M. No. P-05-1999, February 22, 2008, 546 SCRA 403-412; Office of the Court Administrator v. Nacuray, A.M. No. P-03-1739, April 7, 2006, 486 SCRA 532, 541.
[16] Article XI, Section 1.
[17] De la Cruz v. Luna, A.M. No. P-04-1821, August 2, 2007, 529 SCRA 34.
[18] A.M. No. P-06-2103, April 17, 2007, 521 SCRA 365.
[19] Id. at 370.
[20] Edgardo C. Rivera v. Danver A. Buena, Clerk of Court, MeTC, Branch 38, Quezon City, A.M. No. P-07-2394, February 19, 2008, 346 SCRA 222.
[21] Office of the Court Administrator v. Nacuray, supra note 15.
[22] Re: Financial Report on the Audit Conducted in the Municipal Circuit Trial Court, Apalit-San Simon, Pampanga, A.M. No. 08-1-30-MCTC, April 10, 2008.
By Resolution of January 18, 2006,[3] this Court adopted the recommendations of the OCA including the issuance of a Hold Departure Order[4] against respondent.[5]
- The report of the team be docketed as a regular administrative complaint against Mr. Gil B. Reynoso.
- Clerk of Court Gil B. Reynoso be DIRECTED to:
- SUBMIT the following missing documents:
a.1. Missing Official Receipts
And ORs from September 1985 - December 1990
a.2. Unaccounted Official Receipts
7841501 - 7841550 0165901 - 0165950 7841551 - 7841600 0165951 - 0166000 7841601 - 7841650 1391051 - 1391100 7841651 - 7841700 2550501 - 2550550 7841701 - 7841750 2550551 - 2550600
a.3. Original copy of cancelled official receipts
a.4. Passbook of LBP Savings Account No. 0211-0489-56 for the period from March 25, 1996 to July 19, 1996
a.5. Supporting documents of Fiduciary Fund withdrawals (Annex 1)[1]
b. SECURE confirmation from the Land Bank of the Philippines as to the validity of the following unvalidated deposits:
b.1. For Judiciary Development Fund
b.2. For General Fund
c. EXPLAIN in writing within 10 days from notice the following:
c.1. Unreported collection in the Monthly Reports:
c.2. Erroneous reporting of collections in the Monthly Reports:
100.00
c.3. Official Receipts reported as "CANCELLED" in the Monthly Reports but the original copy of the official receipts were not marked "CANCELLED":
3. A Hold Departure Order be ISSUED against Clerk of Court Gil B. Reynoso to prevent him from leaving the country.[2] (Emphasis in the original)
Acting on respondent's Answer[6] which was prepared and signed in California, USA, this Court, on the recommendation of the OCA, required respondent anew to submit the missing documents enumerated in the Resolution of January 18, 2006, except those official receipts which were submitted to the Commission on Audit (COA).[7]
Respondent submitted his Manifestation and Compliance dated March 13, 2006,[8] explaining at length as follows:
That these receipts have been lost or have been unaccounted for in the many years passed, and during his appointment as the OIC-CLERK OF COURT OF THE CITY COURT, after the former Clerk of Court, RICARDO QUERUBIN, took his leave of absence due to health reasons, there was really no formal turnover of the office nor of the used and unused receipts to the undersigned, and he has to make his way through the administration and operation of the office without the usual and formal turnover and accounting of materials and accountabilities usually attendant to the process because of the peculiar situation of the then Clerk of Court.Respondent thereupon prayed that the Court direct its auditors to review the Official and Original Records and files which he submitted to the Accounting Division and the Property Division.[10]
That the Office of the Clerk of Court at that time really did not reflect its importance to the administration of the Courts by its physical situation and was truly without any means to adequately protect and/or keep its necessities and documents because at the time that he was appointed OIC of the said Office, it was merely accommodated by the local government of Lucena City in the City Hall in a small space between Branch I and Branch II of the City Court.
That its office space approximately measured a mere 1.5 m. x 3.5 m., and considering it has to accommodate and house seven (7) employees of the Office of the Clerk of Court, seven (7) tables and their accessories, typewriters, and two (2) steel cabinets, which were already filled to the brim, there was no effective way to really safekeep some of the documents of the said office.
x x x x
That unfortunately, when he was appointed as its OIC of the said office and eventually as the Clerk of Court of the City Court, he was not able to change much of the situation not because of choice but because of the lack of facility and/or a larger area to place the various documents and receipts of the Office of the Clerk of Court.
That in the same circumstance, the record books, docket books, and other books of the office all suffered the same fate because of their numbers and size, and all has to be left in the open.
x x x x
That also, since there was no issue or matter ever raised on the booklets of receipts now required by the Honorable Supreme Court for the undersigned to produce, he has to admit that he had already lost track of the said booklets and has never minded to anymore take importance of the said booklets as the past audits made never required him to account for the same, thus, he truly was of the belief that all was in order and settled.
That not knowing there was any problem or any matter to be settled or accounted for, and in utmost good faith, he never made any effort to correct the usual and regular process by which the funds of his office are reported to the Honorable Supreme Court.
That with all truth and candor, though truly unfortunate, he cannot anymore account the consequent fate of the documents/Official Receipt Booklets identified in the Resolution of the Court dated January 18, 2006, not only because of the situation described above but also because of the lapse or length of time from which to retrace the whereabouts of these booklets of Official Receipts.
That though the undersigned failed to safekeep the said booklets/documents, he can sincerely say that he has never touched or misappropriated any money under his safekeeping though he might have misposted or misdivided the funds in the various accounts to which the payments are supposed to be applied.
x x x x
That though the undersigned cannot produce what the Honorable Court requires, these documents can still be traced and verified as the undersigned had been regularly forwarding his monthly report with the Honorable Supreme Court, through the Accounting Division, with the questioned receipts and documents, whose records will reveal that all funds were properly accounted for in so far as to what he actually received during the said period.
x x x x
That again, there may be missing receipts or cancelled receipts which may not have been properly cancelled by the undersigned as found by the Auditor, but he can vouch and say that all the money or funds pertaining to these missing or cancelled receipts are all with the Supreme Court and/or deposited to the Bank and remitted to the Honorable Supreme Court.
That the undersigned, though he is in a situation where he is bereft of documents to show his innocence, the records of his report to the Accounting Division, Honorable Supreme will verily show that all are in the coffers of the most Honorable Court.
That with respect to the others, most of them were lost and/or misplaced during the time when the Municipal Trial Court was renovated in the year 1990, where the files and records of the Office of the Clerk of Court were displaced and brought together with other records of the MTC, Branches I and II because of the very limited space available in the area provided by the City Hall of Lucena City at that time.
That correspondingly, other records and receipt booklets were lost when the Municipal Trial Court, Branch I and II, and the Office of the Clerk of Court transferred its office in 1995, from the City Hall to the new City Hall Annex as there was no secured storage rooms to temporarily hold the documents and the properties of the Office including those of the trial courts.
That with respect to the original copies of the cancelled official receipts enumerated in Item a.3, these receipts together with other receipts are on file in several folders where receipts for withdrawn bonds were also safekept. All of the duplicate copies of the Official Receipts issued or used by the Office of the Clerk of Court were religiously reported and transmitted to the Chief Accountant of the Supreme Court in Manila, being part of his Monthly Collection Report, though the undersigned has to admit that the cancelled Official Receipts were not reported in the monthly reports of collections submitted by the undersigned respondent and he really cannot say where they were at the present time.
That with respect to the original receipts for cash bonds paid by the bondsman or accused, these are on file or attached to the case records of the cases where the bond was supposedly filed and most of them are still pending or have been archived by the Trial Courts, both Branches I and II, and with regards to the forfeited bonds or cases which have been archived, the original receipts are not with the undersigned respondent as they are still attached to the case records of the cases for which the payments were made.
x x x x
That with respect to the Land Bank Passbook for Saving Account No. 0211-0489-56, the undersigned cannot truly remember where he could have possibly placed it or whether the same was already lost years ago. However, the deposits made in the said passbook were all reflected from the Monthly Reports submitted by the undersigned respondent during the said period. Again, with utmost apologies, he can only suggest that there are available copies in the Accounting Office of the Supreme Court because he had been transmitting to the said Office the duplicate official receipts and deposit slips made and undertaken in the process.
That though there were deposits that were said to be unvalidated, these deposits were actually made to the Bank. The deposit slips for these transactions were attached and transmitted together with his Monthly Reports to the Honorable Supreme Court, though he has to admit that there were instances that the deposit slips and/or withdrawal slips were not stamped mark by the Bank because there were many occasions when his staff failed to have all the duplicate deposits and/or withdrawals properly stamped by the Bank, but the aggregate deposits were properly reflected in the passbook.
That the withdrawal slips must always be signed ahead by the undersigned respondent before the Executive Judge, who sometimes signs only one copy or sometimes two, and naturally, it was the fully and completely signed withdrawal slips that is brought to the Bank while the incomplete withdrawal slip without the signature of the Executive Judge is the one retained or left in the Office of the Clerk of Court. This situation may have created a wrong impression with the Auditors as it would appear that I am withdrawing funds without the knowledge or signature of the Executive Judge.
x x x x
That records, receipts and other documents may have been misplaced or lost records and receipts but there is definitely no funds taken or misappropriated by the undersigned, though the undersigned respondent cannot present them or account for them, the monthly report will be indicative of the status of the funds and account of the Office of the Clerk of Court during the months for which the reports were made and submitted.
That the undersigned respondent may have been careless or by innocent inadvertence, failed to properly safekept the receipts, deposit slips, withdrawal slips, and other documents, but again, the undersigned respondent attest that the funds are all there and intact if not already received by the most Honorable Supreme Court.
x x x x[9] (Italics and uppercasing in the original; emphasis and underscoring supplied)
The Court Management Office presented respondent's Summary of Accountabilities as of February 28, 2005, with a caveat that the "computed liabilities may change upon submission and examination of the missing documents required [of] him," as follows:
By Memorandum dated September 21, 2007, the OCA came up with the following evaluation:
October 1991 to February 2005
February 28, 2006
July 1995 to November 2003
Total Collections Less: Total Remittances Balance of Accountability
December 2003 to February 2005
Total Collections Less: Total Remittances Balance of Accountability
April 1985 to February 2005
Total Collections Less: Total Remittances Balance of Accountability * P18,221.34 arose from the collections and deposits from April 1985 to December 1990 which were solely based on the Subsidiary Ledger of Mr. Reynoso maintained by the Accounting Division, FMO, OCA, because no documents were presented and examined relative to this period.
The above computed accountabilities may change upon submission and examination of the missing documents required [of] him.
x x x x[11] (Emphasis in the original)
Respondent as Clerk of Court has control and supervision over his personnel, properties and supplies in his office. He must be held accountable for the missing official receipts, unaccounted official receipts, original copies of cancelled official receipts, the passbook of LBP Savings Account No. 0211-0489-56 for the period from March 25, 1996 to July 19, 1996 and Supporting Documents of Fiduciary Fund Withdrawals and shortages. The 2002 Revised Manual for Clerks of Court, citing Circular No. 22-94, April 8, 1994 provides:In view of its findings and evaluation, the OCA made the following recommendations:
"In cases wherein cancellation of official receipts becomes inevitable, the Clerk of Court or duly authorized representative, must present to the Provincial/City/Municipal Auditor the spoiled and cancelled receipt/s for inspection. Under no circumstances shall destruction of accountable forms be allowed."Respondent's lengthy ratiocinations such as the missing documents may have been lost during their numerous transfer of office considering the lack of secured storage area for the files; that it may have been commingled with the files from Branch[es] I and II of Municipal Trial Court[,] Lucena and that his attention was never called by the auditors from the Commission on Audit regarding any irregularity in his office will not exonerate him. All of these, taken together just bring to fore the fact that as Clerk of Court, an accountable officer, he miserably failed to live up to his bounden duty. He conveniently forgot that he is an important officer of the judiciary.
"Original copies of cancelled official receipts are to be attached to their duplicate and triplicate copies in the booklet for audit of COA and the Fiscal Monitoring Division."
"In cases of loss of official receipts, the Clerk of Court or the duly authorized representative must immediately report to the [P]rovincial/City/Municipal Auditor and then file an application for relief if the circumstances warrant."
Official receipts are accountable forms and an accounting of their use is required at the end of the term of the Clerk of the Clerk of Court/Accountable Officer."
"Official receipts issued must be properly recorded in their respective books of accounts for accounting and control purposes. Official receipts must be kept in safe custody. The Clerk of Court as the person directly responsible for all court collections must take all reasonable steps to minimize the risk of losses, defalcations and other types of irregularities."
x x x x
Thus[,] he must be held liable for the missing official receipts, unaccounted official receipts, original copies of cancelled official receipts, the passbook of LBP Savings Account No. 0211-0489-56 for the period from March 25, 1996 to July 19, 1996 and Supporting Documents of Fiduciary Fund Withdrawals and for the shortage incurred. It is incumbent upon him to ensure that all the files and documents are properly filed. This, he failed to do. His defenses cannot exonerate him. In fact it even underscored the fact that he was unable to meet the demands of his office. His claims of good faith, his forgetfulness and lack of secured storage area for their files during their transfer of office could only indicate his attempt to evade punishment for his neglect of duty.
The records of the Leave Division of this Office show that the respondent has a total of 505.615 leave credits. Its monetary value can be used partially to cover the shortage in the Fiduciary Fund. This Office opted to give priority to this Fund, being in the nature of a Trust Fund, it does not belong to this Court but to the litigants, many of whom are already claiming the return of their cash bail. It is truly embarrassing whenever we deny these claims for the reason that our own employee absconded with the money.[12] (Emphasis and underscoring supplied)
The evaluation cum recommendations of the OCA is well-taken.
- Clerk of Court Gil B. Reynoso[,] MT[C]C, Luncena City be FOUND GUILTY of gross neglect of duty;
- Respondent be DISMISSED from the service with forfeiture of all retirement benefits, excluding accrued leave credits, with prejudice to re-employment in any government office, including government-owned and controlled corporations;
- That the Financial Management Office, Office of the Court Administrator be DIRECTED to process the terminal leave benefits of the respondent, dispensing with the documentary requirements, and to remit the said benefit[s] to the Fiduciary Account of [MTCC] Lucena City;
- Mr. Reynoso be FOUND GUILTY of contempt of court for failing to return the missing documents despite repeated demands;
- Respondent be directed to RESTITUTE the amount of One Million Nine Hundred Thirty Three Thousand Four Hundred Five and sixty-nine (P1,933,405.69), representing the amount of the shortages[;]
- Director Nestor M. Mantaring, National Bureau of Investigation be DIRECTED to cause the arrest of Mr. Reynoso and to detain him until he complies with the directives of this Court to restitute the above-mentioned shortages.[13] (Emphasis in the original)
Safekeeping of public and trust funds is essential to an orderly administration of justice. No protestation of good faith can override the mandatory nature of the circulars designed to promote full accountability of government funds.[14] The Court has not hesitated to impose the ultimate penalty on those who have fallen short of their accountabilities. Any conduct that would violate the norms of public accountability and diminish, or even merely tend to diminish, the faith of the people in the justice system has never been tolerated or condoned by the Court.[15] This ought to be so, as no less than the 1987 Constitution dictates:
Public office is a public trust. Public officers and employees must at all times be accountable to the people, serve them with utmost responsibility , integrity, loyalty, and efficiency, act with patriotism and justice, and lead modest lives.[16] (Emphasis supplied)Clerks of court are the chief administrative officers of their respective courts. As such, they are duty-bound to use skill and diligence in the performance of their officially designated functions. [17] In Office of the Court Administrator v. Paredes,[18] this Court spelled out anew the nature of the function of clerks of court:
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. Thus, they are liable for any loss, shortage, destruction or impairment of such funds and property.[19]By respondent's assumption of the position of clerk of court, it is understood that he was ready and competent to do his job with utmost devotion and efficiency.[20]
Compounding respondent's liability is his continued unexplained failure to comply with the directives to submit the missing documents mentioned above, which clearly speaks of his disregard of the duty of every employee of the Judiciary to obey the orders and processes of this Court without delay.[21]
Respondent's restitution of the shortages he incurred does not free him from the consequences of his wrongdoing and erase his administrative culpability.[22]
For his failure then to live up to the high ethical standards expected of court employees, respondent's dismissal is indeed in order.
WHEREFORE, this Court finds respondent, Gil B. Reynoso, GUILTY of gross neglect of duty. He is ordered DISMISSED from the service with forfeiture of all retirement benefits, excluding accrued leave credits, with prejudice to re-employment in any government office, including government-owned and controlled corporations.
For his failure to return the missing documents despite repeated orders of this Court, he is found GUILTY of contempt of court and is ordered to pay a FINE of Five Thousand (P5,000) Pesos and to submit all the required documents to the OCA within thirty days from receipt of this Decision.
The Financial Management Office, Office of the Court Administrator, is DIRECTED to process the terminal leave benefits of respondent with dispatch and apply the same to his accountabilities, giving priority to the Fiduciary Fund Account of MTCC-Lucena City.
Upon submission of the missing documents by respondent, the Financial Management Office, Office of the Court Administrator, is DIRECTED to compute the remaining accountabilities of respondent, if any, and to submit a report thereon within thirty days from compliance of respondent.
Respondent is ordered to RESTITUTE the difference of One Million Nine Hundred Thirty-Three Thousand Four Hundred Five Pesos and Sixty-Nine Centavos (P1,933,405.69) and whatever amount that will be remitted by the Financial Management Office of the Office of the Court Administrator.
The Office of the Court Administrator is DIRECTED to initiate appropriate criminal proceedings against respondent in light of the above findings of the Court.
SO ORDERED.
Quisumbing, (Acting C.J.), Carpio, Austria-Martinez, Corona, Carpio Morales, Tinga, Chico-Nazario, Nachura, Leonardo-De Castro, Brion, and Peralta, JJ. , concur.
Puno, C.J., Ynares-Santiago, Azcuna, and Velasco, Jr., JJ., on official leave.
[1] The total amount is P1,776,642.90.
[2] Rollo, pp. 1-7.
[3] Id. at 87-94.
[4] Id. at 95-103.
[5] By letter of February 28, 2006, Executive Judge Romeo L. Villanueva informed the Court that respondent left for the United States of America on October 21, 2005 and has not yet returned as of the time of writing of the letter. The January 18, 2006 Resolution of the Court and the Hold Departure Order of even date were received by the eldest daughter of respondent on February 4, 2006.
[6] Rollo, pp. 148-154.
[7] Rollo, p. 186.
[8] Id. at 188-198.
[9] Id. at 189-196.
[10] Id. at 197.
[11] Id. at 202.
[12] Id. at 215-217.
[13] Id. at 217-218.
[14] Re: Financial Audit on the Accountabilities of Mr. Restituto A. Tabucon, Jr., Former Clerk of Court II of the MCTC, Ilog, Candoni, Negros Occidental,A.M. No. 04-8-1-195-MCTC, August 18, 2005, 467 SCRA 246, 250.
[15] Angeles A. Velasco v. Atty. Prospero V. Tablizo, A.M. No. P-05-1999, February 22, 2008, 546 SCRA 403-412; Office of the Court Administrator v. Nacuray, A.M. No. P-03-1739, April 7, 2006, 486 SCRA 532, 541.
[16] Article XI, Section 1.
[17] De la Cruz v. Luna, A.M. No. P-04-1821, August 2, 2007, 529 SCRA 34.
[18] A.M. No. P-06-2103, April 17, 2007, 521 SCRA 365.
[19] Id. at 370.
[20] Edgardo C. Rivera v. Danver A. Buena, Clerk of Court, MeTC, Branch 38, Quezon City, A.M. No. P-07-2394, February 19, 2008, 346 SCRA 222.
[21] Office of the Court Administrator v. Nacuray, supra note 15.
[22] Re: Financial Report on the Audit Conducted in the Municipal Circuit Trial Court, Apalit-San Simon, Pampanga, A.M. No. 08-1-30-MCTC, April 10, 2008.