In Office of the Court Administrator v. Atty. Edgar Allan C. Morante, the Supreme Court affirmed the dismissal of a Clerk of Court for grave misconduct after he was caught extorting money to influence a court decision. The Court emphasized that public office is a public trust, requiring the highest standards of moral righteousness and uprightness, especially from those involved in the administration of justice. This ruling reinforces the judiciary’s commitment to weeding out corruption and maintaining public confidence in the legal system, reminding court employees that they are held to the strictest standards of integrity and accountability.

Justice for Sale: Did a Court Clerk’s Greed Tarnish the Scales of Justice?

The case began with an anonymous letter exposing alleged corruption by Atty. Edgar Allan C. Morante, a Branch Clerk of Court. Attached was a news clipping detailing his arrest for allegedly receiving P200,000 to fix a court decision. An investigation ensued, leading to a formal inquiry by Justice Narciso Atienza, who ultimately recommended Morante’s dismissal. The core issue revolved around whether Morante extorted money from a litigant in exchange for favorable resolution of a libel case, a grave breach of public trust and judicial ethics.

The complainant’s case centered on the testimony of Tetsuo Momma, a Japanese citizen, and his executive secretary, Jose “Joey” Olavere. Momma was facing a libel charge when Olavere alleged that Morante demanded P250,000 for a favorable decision, initially requiring P50,000 for an unsigned copy of the dismissal order. Olavere reported the extortion to the NBI, leading to an entrapment operation where Morante received P200,000 in exchange for a signed order dismissing the libel case. This operation formed the basis for both criminal and administrative charges against Morante.

Morante vehemently denied the charges, claiming that Olavere attempted to bribe him and that the money was placed on his desk without his knowledge. He presented witnesses who testified to his character and the circumstances surrounding the alleged entrapment. He further argued that Olavere and Momma recanted their statements, weakening the case against him. However, the Court found these defenses unpersuasive.

In administrative proceedings, the standard of proof is substantial evidence, defined as “that amount of relevant evidence which a reasonable mind might accept as adequate to support a conclusion.” The Court emphasized that evidence to support a conviction in a criminal case is not necessary in administrative proceedings; the integrity demanded of members of the Bench is not satisfied by merely allowing one to escape criminal penalties. The dismissal of a criminal case against the respondent is not a ground for the dismissal of the administrative case.

The Court gave weight to Olavere’s testimony and sworn statement, finding that he received the unsigned order after paying Morante P50,000. The Court highlighted that even with inconsistencies in Olavere’s testimony, it was corroborated by other evidence. Additionally, the Court found Morante’s preparation of the unsigned order, containing his initials, significant evidence of his involvement. Morante’s defense of denial was insufficient to overcome the evidence presented against him. Key to the Court’s finding was Morante’s violation of procedure when he personally released the signed order to Olavere.

The Court ruled that the recantations by Olavere and Momma did not automatically exonerate Morante. Retractions are viewed with disfavor due to the possibility of intimidation or monetary influence, and the recanting witness should be cross-examined, something the respondent did not move for. The desistance of witnesses does not automatically result in the dismissal of an administrative case. This disciplinary authority cannot be dependent on or frustrated by private arrangements between parties.

The Court unequivocally condemned Morante’s actions, underscoring the need for utmost integrity in the judiciary. Public office is a public trust, and clerks of court, as chief administrative officers, must be individuals of competence, honesty, and probity. Morante’s grave and serious misconduct, consisting of extortion and soliciting bribes, warranted his dismissal from service. As an attorney, Morante also had obligations to uphold the Code of Professional Responsibility, applicable even to those in government service. The integrity of those who serve the public is of utmost importance, with a clear focus on those working in the administration of justice.

FAQs

What was the key issue in this case?	The central issue was whether Atty. Edgar Allan C. Morante, as Clerk of Court, was guilty of grave misconduct for extorting money in exchange for a favorable court decision. This involved assessing the evidence of bribery and whether it met the standard for administrative liability.
What evidence did the complainant present?	The complainant presented testimonies from Jose Olavere, NBI agents, and forensic evidence. These pieces of evidence detailed the entrapment operation and Morante’s involvement in receiving money for a favorable decision.
What was the respondent’s defense?	Morante denied the charges, claiming that Olavere attempted to bribe him and that he had no knowledge of the money. He presented witnesses to support his character and claimed Olavere and Momma recanted their statements.
What standard of proof is required in administrative cases?	Administrative cases require substantial evidence, which is that amount of relevant evidence a reasonable mind might accept as adequate to support a conclusion. This is a lower standard than the proof beyond reasonable doubt required in criminal cases.
What was the effect of Olavere’s retraction?	The court deemed that retraction is not binding because the witness was never presented for further trial or scrutiny. The court noted that retractions are frowned upon due to the possibility of coercion, making his retraction ineffectual to reverse course of action.
What were the Court’s considerations regarding Olavere’s testimony?	The Court considered the entirety of Olavere’s testimony, giving weight to the fact that, despite some inconsistencies, his statements were corroborated by other evidence. The Court also noted that Olavere personally dealt with the respondent.
What made the court believe Morante himself prepared the unsigned order?	The court found the initial “eacm” on the last page of the document, to be made by Morante. Additional proof was gathered from the fact that most paragraphs of the signed and unsigned documents are the same.
Why did the NBI agent testify when Olavere made a report?	To confirm Olavere gave an affidavit, reporting that he was asked to give P250,000 in exchange for an order to remove a person’s hold departure order.
Why did the court proceed despite desistance of main witnesses?	There were two main points the court mentioned in their decision, they could have been threatened or been provided monetary value and because, desistance of a party is never the main cause for dismissal of an admin matter.

This case serves as a stark reminder of the high ethical standards expected of court personnel and the serious consequences of engaging in corrupt practices. The Supreme Court’s decision underscores the judiciary’s commitment to maintaining integrity and public trust by holding accountable those who abuse their positions for personal gain.

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: OFFICE OF THE COURT ADMINISTRATOR vs. ATTY. EDGAR ALLAN C. MORANTE, A.M. No. P-02-1555, April 16, 2004