Re: Disapproval of Appointment of De Leon
REITERATIONFacts
The Antecedents: The Supreme Court forwarded the promotional appointment of Godofredo C. De Leon (respondent) from Utility Worker I to Clerk III in the Regional Trial Court (RTC), Branch 40, Manila, to the Civil Service Commission (CSC) for approval. In support, the respondent submitted a Personal Data Sheet (PDS) indicating he was a Career Service Sub-Professional eligible and a Report of Rating allegedly showing he passed the Career Service Sub-Professional examination in 1977. The CSC disapproved the appointment, certifying that the respondent's name was not on the masterlist of eligibles and that the claimed eligibility belonged to his brother, Reynaldo C. De Leon, whose name was tampered with on the submitted Report of Rating. Procedural History: The Office of the Court Administrator (OCA) directed the respondent to show cause why no disciplinary action should be taken. He failed to comment despite an extension. The CSC filed a Formal Charge for Dishonesty. The respondent filed a counter-affidavit claiming inadvertent inclusion of his brother's eligibility and denial of tampering. After further directives, he submitted an Explanation/Comment admitting he changed his brother Reynaldo's name to Godofredo on the CSC Report of Rating and pleaded for mercy for his family's welfare. The matter was referred to the OCA for evaluation, which found the respondent guilty of Dishonesty and Falsification of Official Document, recommending dismissal. The Petition: This administrative matter concerns the disapproval of the respondent's promotional appointment and the subsequent disciplinary action taken against him.
Issue(s)
Whether the respondent is guilty of dishonesty and falsification of a public document. Whether the respondent's acts warrant dismissal from the service.
Ruling
The respondent Godofredo C. De Leon is hereby DISMISSED from the service with prejudice to reemployment in any government agency, including government-owned and controlled corporations. He shall additionally forfeit any retirement benefit due him, except accrued leaves, if any.
Ratio Decidendi
On whether the respondent is guilty of dishonesty and falsification of public document: The respondent is guilty of dishonesty and falsification of public document. His initial claim of inadvertent inclusion of his brother's eligibility contradicted his PDS and eventually led to his admission that he altered the CSC Report of Rating by changing his brother Reynaldo's name to his own. These acts constitute falsity in a material fact and deception, fitting the definition of dishonesty. The Court emphasized that dishonesty is a malevolent act with no place in the judiciary, which demands the highest standards of integrity, probity, uprightness, honesty, and diligence from all its employees. The respondent's actions directly contravened these principles. On whether the respondent's acts warrant dismissal from the service: The respondent's acts of falsifying and submitting a falsified Certificate of Eligibility and making a false statement in his PDS are grave offenses under Section 23, Rule XIV of the Omnibus Civil Service Rules and Regulations. These offenses warrant the penalty of dismissal from the service, even for the first offense. The Court cited Civil Service Commission v. Sta. Ana where a similar offense of submitting a spurious Certificate of Eligibility led to dismissal. While the respondent's remorse and motivation for his family's welfare were acknowledged, the Court held that these cannot excuse a transgression of law and established norms of conduct. His actions demonstrated unfitness to perform duties with the integrity required in the Judiciary.
Main Doctrine
Dishonesty and falsification of public documents are grave offenses under civil service rules that warrant dismissal from the service, even for the first offense, as public officers and employees must uphold the highest standards of integrity and honesty.