In Mario R. Barrozo and Richanne Cherry Herrero v. Rosalie D. Sarsagat, A.M. No. P-25-293 (formerly JIB FPI No. 24-454-P), June 3, 2026, the Supreme Court En Banc dismissed a court stenographer for participating in a bogus annulment scheme. More importantly, the decision clarifies how gross misconduct is established under the 2025 Code of Conduct and Accountability for Court Officials and Personnel (CCACOP).
The facts
Mario Barrozo, an OFW, paid ₱250,000 through an intermediary, Phyllis Castañeda, for the supposed annulment of his marriage. Court stenographer Rosalie Sarsagat later personally gave Barrozo a purported RTC decision declaring his marriage void, together with supposed certificates of finality and authenticity.
The documents were fictitious. The RTC had no record of the case.
Sarsagat subsequently obtained another ₱30,000 from Barrozo, supposedly for registration of the annulment. Bank records identified Sarsagat as the recipient and stated that the payment was for “Process for Registration of Annulment.”
Ratio decidendi
The controlling reasoning is that misconduct becomes gross misconduct when the violation is serious and is attended by corruption, clear willful intent to violate the law, or flagrant disregard of established rules, proved by substantial evidence.
The Court found substantial evidence of corruption. Barrozo positively identified Sarsagat as the court employee who handed him the fabricated judicial documents. Her connection with Phyllis Castañeda, the messages attributed to her, and her initials appearing on the certificates corroborated his account.
The Court rejected Sarsagat's general denial. A bare denial, standing against substantial affirmative evidence, is inherently weak and self-serving.
Significantly, the Court found two separate counts of gross misconduct: first, Sarsagat's participation in the sham annulment transaction and delivery of the fake judicial documents; second, her subsequent demand and receipt of ₱30,000 under the false representation that it would be used for registration.
The Court also applied the 2025 CCACOP to the pending case, because the new Code expressly applies to pending and future cases unless retroactive application is infeasible or would work injustice.
Why the case matters
The decision reinforces a fundamental rule of judicial ethics: court personnel must not merely avoid actual corruption; they must avoid conduct that undermines public confidence in the Judiciary.
Sarsagat's prior administrative offense also aggravated the situation. The Court therefore dismissed her, forfeited her retirement benefits except accrued leave credits, barred her from government reemployment, and ordered her to return ₱30,000.
The case is a strong reminder that the integrity of the Judiciary does not depend solely on judges and justices. Every court employee is an officer of the justice system, and participation in fraudulent judicial transactions can result in the ultimate administrative penalty.
Official source: Supreme Court E-Library, Barrozo and Herrero v. Sarsagat, A.M. No. P-25-293, June 3, 2026.
[Supreme Court E-Library decision](https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70572?utm_source=chatgpt.com)
(Assisted by ChatGPT AI research)
