Re: Dropping from the Rolls of Pijana
REITERATIONFacts
The Antecedents: Ms. Laydabell G. Pijana (Pijana), Sheriff IV at the Regional Trial Court of Tagaytay City, Cavite, Branch 18, had been absent without official leave (AWOL) since March 1, 2018, having neither submitted her Daily Time Record (DTR) nor filed any application for leave. She had not reported for work to date, and her salaries and benefits were withheld. The Office of the Court Administrator (OCA) confirmed that Pijana was still in the court personnel plantilla, considered in active service, but was no longer on the payroll, had no pending retirement application, and was not an accountable officer. Nine (9) administrative cases were pending against her. Procedural History: The OCA recommended that Pijana be dropped from the rolls effective March 1, 2018, for being absent without official leave for more than thirty (30) working days. It also recommended that her position be declared vacant and that she be informed of her separation at her last known address. The OCA noted that Pijana remained qualified to receive accrued benefits and could be reemployed, without prejudice to the outcome of the pending administrative cases. The Petition: The Supreme Court reviewed the OCA's findings and recommendation.
Issue(s)
Whether Laydabell G. Pijana should be dropped from the rolls for absence without official leave. Whether her separation from the service should result in forfeiture of benefits or disqualification from government service.
Ruling
The Supreme Court adopted the findings and recommendations of the OCA. Laydabell G. Pijana was dropped from the rolls effective March 1, 2018, and her position was declared vacant. She remains qualified to receive accrued benefits and may be reemployed, without prejudice to the outcome of pending administrative cases.
Ratio Decidendi
On whether Laydabell G. Pijana should be dropped from the rolls for absence without official leave: The Court ruled in the affirmative, citing Section 107, Rule 20 of the 2017 Rules on Administrative Cases in the Civil Service (2017 RACCS) and Section 63, Rule XVI of the Omnibus Rules on Leave, as amended. These provisions clearly state that an official or employee continuously absent without official leave for at least thirty (30) working days may be dropped from the rolls without prior notice. Pijana's absence since March 1, 2018, without any leave application, squarely falls within this ground. The Court emphasized that prolonged unauthorized absence causes inefficiency in public service, disrupts court functions, and contravenes the duty of a public servant to serve with utmost responsibility, integrity, loyalty, and efficiency. Pijana's failure to report for work demonstrated a gross disregard and neglect of her duties, failing to adhere to the high standards of public accountability. On whether her separation from the service should result in forfeiture of benefits or disqualification from government service: The Court clarified that this case was non-disciplinary in nature. Therefore, Pijana's separation from the service would not result in the forfeiture of any accrued benefits nor her disqualification from government service, pursuant to Section 110 of the 2017 RACCS. This is without prejudice to the outcome of the nine (9) administrative cases still pending against her. The Court stressed the importance of upholding public accountability and maintaining people's faith in the judiciary, noting that a court personnel's conduct carries a heavy burden of responsibility.
Main Doctrine
An employee continuously absent without official leave for at least thirty (30) working days may be dropped from the rolls without prior notice, subject to the right to appeal.