Aldecoa-Delorino v. Remigio-Versoza
REITERATIONFacts
The Antecedents: Complainant Judge Jenny Lind Aldecoa-Delorino filed a letter-complaint against respondent Marilyn de Castro Remigio-Versoza, Clerk III, for falsification of school records and dishonesty. Respondent applied for the position of Clerk III and submitted an Official Transcript of Records (OTR) indicating she completed two years of Bachelor of Science in Secretarial Education at the Polytechnic University of the Philippines (PUP) from 1976-1978. She also indicated this in her Personal Data Sheet (PDS) dated June 8, 2001. It was later discovered that respondent did not actually take the said course, though her actual educational attainment could not be ascertained. Additionally, respondent was accused of using the payslip of Catherine Aceveda, without consent, to support a credit card application by superimposing her name and TIN over Aceveda's. Procedural History: The complaint was referred to the Office of the Court Administrator (OCA) for investigation. Respondent, in her Comment, admitted that the OTR had alterations but denied personal tampering, blaming an officemate, Rowena Ramos. Respondent also denied using Aceveda's payslip. Respondent filed a counter-complaint against Judge Aldecoa-Delorino, accusing her of hiring an outsider to draft decisions. The OCA recommended that the complaint against respondent be re-docketed as a regular administrative matter and respondent's comment be treated as a counter-complaint. The Court re-docketed the case and required the complainant to comment on the counter-complaint. Complainant denied the counter-charge as retaliation and attached a letter from the PUP Registrar confirming the OTR was falsified. The OCA, in its report, found sufficient evidence to hold respondent liable for falsification of the transcript of records and recommended dismissal. The OCA also found the counter-complaint against Judge Delorino to be without merit. The Petition: The Supreme Court reviewed the case based on the OCA's findings and recommendations.
Issue(s)
Whether respondent Marilyn de Castro Remigio-Versoza is guilty of dishonesty and falsification of public documents. Whether the counter-complaint filed by respondent against complainant Judge Jenny Lind Aldecoa-Delorino is meritorious.
Ruling
The Supreme Court found respondent Marilyn de Castro Remigio-Versoza guilty of dishonesty and falsification of public records and ordered her dismissal from the service. The counter-charge against Judge Aldecoa-Delorino was dismissed for lack of merit.
Ratio Decidendi
On the issue of dishonesty and falsification of public documents: The Court held that respondent is guilty of dishonesty and falsification of public documents. Respondent falsely indicated in her PDS that she finished a B.S. Secretarial course at PUP, appending a falsified OTR to support this claim. The PUP Registrar confirmed the OTR was a falsified document that did not originate from the school. Even if another person prepared the falsified documents, respondent's act of allowing these falsified records to become part of her employment records, coupled with her sworn statement in the PDS, made her equally liable. The Court emphasized that the Judiciary demands the highest degree of moral righteousness and uprightness, and an employee with long years of experience is expected to possess a higher degree of rectitude and honesty. Dishonesty, defined as intentionally making a false statement on any material fact or practicing deception, and falsification of a public document are grave offenses warranting dismissal from the service, even for a first offense. The Court cited previous cases where similar offenses led to dismissal. On the issue of the counter-complaint against Judge Aldecoa-Delorino: The Court dismissed the counter-complaint for lack of merit. Respondent's allegations that the complainant hired an outsider to draft decisions were unsubstantiated and appeared to be an attempt to divert attention from her own falsification. The Court reiterated that in administrative proceedings, the burden of proof lies with the party making the allegation, and respondent failed to substantiate her charges. The Court warned that it would not tolerate baseless counter-administrative suits and would enforce the law strictly against court personnel found to be unfit for the integrity and dignity of the institution.
Main Doctrine
A court employee who misrepresents their educational attainment in their Personal Data Sheet (PDS) and submits a falsified Official Transcript of Records (OTR) to qualify for a position commits dishonesty and falsification of a public document, which are grave offenses warranting dismissal from the service.