Office of the Court Administrator v. Ampong
REITERATIONFacts
The Antecedents: The Office of the Court Administrator (OCA) received an inquiry from Executive Judge Jaime L. Infante regarding the employment status of respondent Sarah P. Ampong, a Court Interpreter III, who had been dismissed from service by the Civil Service Commission (CSC) but remained employed and received her salary and benefits. Procedural History: An administrative case was instituted against Ampong by the CSC in August 1994 for impersonating Evelyn B. Junio-Decir in the November 1991 Civil Service Eligibility Examination for Teachers. Ampong admitted the charges, and the CSC dismissed her from service on March 21, 1996. Ampong's motion for reconsideration was denied, and her petition for review before the Court of Appeals (CA) was also denied on November 30, 2004, affirming her dismissal. Subsequently, the Supreme Court En Banc denied her petition for review on certiorari on August 26, 2008 (G.R. No. 167916), affirming her dismissal. The Petition: Despite the Supreme Court's August 26, 2008 Decision, the Financial Management Office (FMO) of the OCA continued to release Ampong's salaries and allowances due to not receiving official directives. Upon notification by Judge Infante, the FMO began withholding her salaries in June 2011. Ampong, in her Comment, prayed for the Court to revisit its final ruling in G.R. No. No. 167916 and reiterated her argument regarding the CSC's lack of jurisdiction.
Issue(s)
Whether or not respondent Sarah P. Ampong had been dismissed from her employment as Court Interpreter III of the RTC. Whether the Civil Service Commission had jurisdiction over Ampong's case despite her subsequent appointment to the judiciary.
Ruling
The Court resolved the issue in the affirmative. Respondent Sarah P. Ampong was dismissed from her employment as Court Interpreter III. The Court sustained her dismissal on the ground of Dishonesty, ordered the forfeiture of her retirement and other benefits except accrued leave credits, and perpetually disqualified her from re-employment in any government agency.
Ratio Decidendi
On whether respondent Sarah P. Ampong had been dismissed from her employment as Court Interpreter III of the RTC: The Court affirmed that Ampong had indeed been dismissed from service. This dismissal stemmed from the Supreme Court's August 26, 2008 Decision in G.R. No. 167916, which affirmed the Civil Service Commission's resolution dismissing her for dishonesty. The Court emphasized the principle of immutability of judgment, stating that a final and executory decision cannot be modified. Therefore, the penalty of dismissal imposed on Ampong for her dishonest act must be enforced in its full course. The Court reiterated that dishonesty, defined as a disposition to lie, cheat, deceive, or defraud, renders an employee unfit for judicial service. Ampong's act of impersonating another examinee in a civil service examination unequivocally constitutes dishonesty. The Court stressed that employees of the Judiciary must embody integrity and honesty, and Ampong's failure to meet these stringent standards justified her dismissal. On whether the Civil Service Commission had jurisdiction over Ampong's case despite her subsequent appointment to the judiciary: The Court held that administrative jurisdiction over a court employee belongs to the Supreme Court, irrespective of when the offense was committed. While the Civil Service Commission has administrative jurisdiction over the civil service in general and the power to control and supervise examinations, the Supreme Court exercises exclusive administrative supervision over all courts and judicial personnel. The Court clarified that in cases involving judicial employees committing irregularities in civil service examinations, the CSC may file charges before the Office of the Court Administrator (OCA), a procedure validated by the Supreme Court. The Court further explained that even if Ampong committed the dishonest act before her appointment to the RTC, it did not divest the Supreme Court of its administrative reach over her as a judicial employee. The Court cited previous cases where similar violations by judicial employees led to charges filed before the OCA, underscoring that the Supreme Court's supervisory power over its personnel is paramount and extends to offenses committed prior to their entry into the judiciary.
Main Doctrine
The Supreme Court retains administrative jurisdiction over court employees regardless of whether the offense was committed before or after their appointment to the judiciary. A final judgment of dismissal from service due to dishonesty must be enforced.