Lauria-Liberato v. Lelina

A.M. No. P-09-2703 (September 5, 2011)

Lelina fined P40,000 for falsifying an affidavit, highlighting court personnel integrity.

Facts:

The case involves an administrative complaint filed by Lina Lauria-Liberato against Nestor M. Lelina, the Clerk of Court II of the Municipal Circuit Trial Court of Naguilian-Reina Mercedes, Isabela. The complaint, dated May 14, 1999, and filed on June 8, 1999, alleges grave misconduct, dishonesty, and conduct prejudicial to the best interest of the service. The basis of the complaint stems from allegations that Lelina falsified an Affidavit of Relinquishment to enrich himself at the expense of Lauria-Liberato and her family.

Lauria-Liberato claims to be the granddaughter of Candido Lauria, who died on December 13, 1974, and was the original owner of Lot No. 4213 Cad-389-D. She asserts that her grandfather allowed Lelina to occupy a portion of the property under the condition of paying monthly rent, which he failed to do. In March 1999, Lauria-Liberato discovered that the property had been titled in Lelina's name based on an Affidavit of Relinquishment dated October 3, 1997, which purportedly stated that Candido Lauria relinquished his rights to the property in favor of Lelina. Lauria-Liberato contends that this affidavit is invalid as her grandfather had already passed away in 1974.

The complaint further alleges that Lelina used the falsified affidavit to support his application for a free patent over the property, resulting in the issuance of Original Certificate of Title (OCT) No. P-72874 in his name. Subsequently, this title was subdivided into three lots, which Lelina mortgaged for P225,000.00. Lauria-Liberato also filed a criminal complaint against Lelina for Estafa through Falsification of Public Documents.

In his defense, Lelina claimed co-ownership of a portion of the property, asserting that he acquired it from the heirs of Dionisio Lauria, Candido's son. He argued that he was acting on an agreement with Juana Lauria, Candido's daughter, to facilitate the registration of the property, with the understanding that it would eventually be reconveyed to the heirs. Lelina denied any intent to defraud and provided evidence of his financial standing to counter the allegations.

The administrative complaint was deferred pending the outcome of the criminal case against Lelina. In August 2003, the Regional Trial Court found Lelina guilty of Estafa through Falsification of Public Document, sentencing him to imprisonment and ordering the reconveyance of the properties to the heirs of Candido Lauria. This decision was affirmed by the Court of Appeals.

Legal Issues:

  1. Whether Nestor M. Lelina committed grave misconduct and dishonesty in the performance of his duties as Clerk of Court II.
  2. The implications of Lelina's actions on the integrity of the Judiciary.
  3. The appropriate administrative penalty for Lelina given his conviction in the criminal case and subsequent retirement.

Arguments:

Complainant's Arguments:

  • Lauria-Liberato contended that Lelina falsified the Affidavit of Relinquishment, which was impossible as Candido Lauria had died in 1974.
  • She argued that Lelina's actions constituted grave misconduct and dishonesty, undermining the integrity of the Judiciary.
  • The complainant emphasized that Lelina enriched himself at the expense of her family, which warranted severe administrative sanctions.

Respondent's Arguments:

  • Lelina claimed that he had a legitimate claim to a portion of the property and that he was acting under an agreement with the heirs of Candido Lauria.
  • He argued that his actions were not motivated by malice or intent to defraud, and he had already reconveyed the property to the heirs.
  • Lelina maintained that his conduct did not involve any abuse of his position as Clerk of Court II.

Court's Decision and Legal Reasoning:

The Court found Lelina guilty of grave misconduct and dishonesty. It emphasized that as a Clerk of Court, he was expected to uphold the highest standards of integrity and propriety. The Court noted that Lelina's execution of the Affidavit of Relinquishment, which falsely claimed that a deceased person had personally relinquished property rights, was a serious violation of ethical standards and constituted a willful perversion of the truth.

The Court highlighted that misconduct involves unlawful behavior or gross negligence by a public officer, and in this case, Lelina's actions were deemed gravely injurious to the Judiciary's reputation. The Court also clarified that the administrative case could proceed independently of the criminal case, and the restitution of the property did not absolve him of administrative liability.

Despite Lelina's claims of having reconveyed the property, the Court found that this did not mitigate his misconduct. The Court ultimately decided to impose a fine of P40,000.00, to be deducted from his retirement benefits, with prejudice to reemployment in any government position, given that he had compulsorily retired prior to the decision.

Significant Legal Principles Established:

  • The case underscores the high standards of conduct expected from court personnel, particularly Clerks of Court, who are tasked with maintaining the integrity of the Judiciary.
  • It establishes that grave misconduct and dishonesty can lead to severe administrative penalties, including dismissal or fines, even after retirement.
  • The ruling affirms that administrative liability can persist independently of criminal liability, ensuring accountability for actions that undermine public trust in the justice system.