Re: Bantog
REITERATIONFacts
The Antecedents: Ms. Lilian B. Bantog, Court Stenographer III, RTC, Pasig City, Branch 168, was absent from office since January 4, 1999. Despite several reminders and warnings, she failed to report for work regularly. On July 19, 2000, the RTC Branch Clerk of Court issued a Memorandum directing her to report for work within five (5) days and explain why she should not be dropped from the rolls. While she reported on July 25, 2000, she failed to provide the required explanation and subsequently absented herself again on July 27 and 28, 2000, with her last reported day being July 31, 2000. She has been on absence without official leave since then. Procedural History: On September 8, 2000, the branch clerk of court recommended her summary dismissal to the Court Administrator. The acting Presiding Judge also indorsed this recommendation. Subsequently, the Supreme Court en banc directed the withholding of her salaries and benefits. The Petition: This administrative case concerns the habitual absence of Ms. Bantog and the recommendation for her dismissal from the service.
Issue(s)
Whether Ms. Lilian B. Bantog's prolonged and repeated absences constitute habitual absenteeism warranting dismissal from service. Whether Ms. Bantog's explanation for her absences, citing marital woes and family problems, sufficiently justifies her conduct.
Ruling
The Supreme Court ordered the dropping of Ms. Lilian B. Bantog from the rolls, effective July 27, 2000, for habitual absenteeism and habitual neglect of duty.
Ratio Decidendi
On Issue 1: The Court found that Ms. Bantog's absences, spanning from January 4, 1999, with specific instances detailed throughout 1999 and continuing into 2000, clearly constituted habitual absenteeism. The records showed a pattern of prolonged and repeated absences without official leave. The Court emphasized that such conduct amounts to habitual neglect of duty, which is a ground for dismissal from the service under Civil Service Rules and Regulations. The repeated nature of her absences, despite warnings, demonstrated a disregard for her official responsibilities and the rules governing government employment. The Court noted that her failure to report for work after July 31, 2000, solidified the finding of habitual absence without official leave. On Issue 2: While Ms. Bantog admitted her habitual absenteeism and cited personal difficulties such as marital woes, her children's matriculation problems, and her husband's lack of employment as contributing factors, the Court found these explanations insufficient to justify her prolonged absence. In her letter dated April 17, 2000, she pleaded for understanding and promised to reform her work habits. However, the records clearly showed that this promised reform was not fulfilled, as her absences continued even after this plea. The Court reiterated that while personal difficulties may be considered, they do not excuse persistent and unexcused absences from duty, especially when the employee has been given opportunities to explain and correct her behavior. The Court stressed that the demands of public service require consistent attendance and dedication, which Ms. Bantog failed to demonstrate.
Main Doctrine
Habitual absenteeism, even if explained by personal difficulties, constitutes habitual neglect of duty and may warrant dropping from the rolls if not corrected after due notice and hearing.