The Supreme Court ruled that falsification of official documents, such as Daily Time Records (DTRs), constitutes dishonesty and warrants dismissal from public service. This decision underscores the high ethical standards expected of public servants, especially those in the judiciary, and reinforces the principle that public office is a public trust. The Court emphasized that falsifying DTRs not only demonstrates a lack of integrity but also undermines public confidence in the judicial system. The ruling sends a clear message that dishonesty and duplicity will not be tolerated, and those who engage in such conduct will face severe consequences.

Broken Trust: When Court Employees Falsify Records in Naga City

This case arose from a series of administrative complaints and counter-complaints among the personnel of the Regional Trial Court (RTC) of Naga City, Branch 27, involving allegations of dishonesty, misconduct, and falsification of official documents. The central figures were Perpetua Socorro M. De Leoz, a court stenographer, and Atty. Amelia B. Vargas, the Branch Clerk of Court, and Melinda F. Pimentel, a Legal Researcher. The Supreme Court consolidated these cases to determine the culpability of the individuals involved and to uphold the integrity of the judiciary. The primary issue revolved around the falsification of Daily Time Records (DTRs) and the extent to which the employees were involved in or aware of these fraudulent activities. The charges included allegations of employees not reporting for work while still claiming salaries, and counter-charges of falsifying attendance records.

The administrative cases began with Melinda F. Pimentel accusing Perpetua Socorro M. De Leoz of violating Supreme Court Circular No. 5-88 by engaging in private business during office hours. This circular prohibits judiciary officials and employees from engaging in activities, such as being commissioned as insurance agents, that could compromise their efficiency and dedication to government service. De Leoz denied these allegations, presenting affidavits from Finchley Design, Inc. and the House of SARA LEE, asserting that she was not a sales agent for either company. Meanwhile, Rolando F. Orante, Perpetua Socorro M. De Leoz, and Maria Leonora S. Puto jointly charged Atty. Amelia B. Vargas and Melinda F. Pimentel with “Gross Dishonesty, Grave Misconduct, and Falsification of Official Documents.”

The core of this charge was that Atty. Vargas and Pimentel allegedly conspired to make it appear that Pimentel had reported for work from April 1 to August 14, 1994, by submitting falsified DTRs. It was alleged that Pimentel was actually reviewing for the 1994 Bar Examination during this period and did not regularly report to the office. Atty. Vargas, as the Branch Clerk of Court, verified and signed these DTRs, enabling Pimentel to receive her salaries and benefits despite her alleged absence. Atty. Vargas and Pimentel denied these accusations, claiming that the complainants had malicious motives. Pimentel admitted attending a Pre-Bar Review Course but insisted that the classes were held after office hours. The Supreme Court’s Leave Section confirmed that Pimentel had not filed any leave of absence for the period in question, further supporting the claim of falsification.

Atty. Amelia Vargas then filed a complaint against Perpetua Socorro M. De Leoz, accusing her of falsifying her own DTRs for May and June 1995. Atty. Vargas claimed that De Leoz made it appear that she reported for work regularly when she was either late or absent. De Leoz countered that Atty. Vargas filed the case to harass her because of the administrative case De Leoz and her colleagues had filed against Atty. Vargas and Pimentel. Perpetua Socorro M. De Leoz also reported that the entries in Melinda F. Pimentel’s DTRs for several dates in June and July 1995 were false. De Leoz alleged that Pimentel merely inserted her signature to make it appear that she was present, and Atty. Vargas certified these entries, knowing they were inaccurate. The Supreme Court treated De Leoz’s letter as an administrative complaint for falsification of official documents and consolidated it with the other cases.

Initially, the parties attempted to settle their differences, submitting a joint letter to the Chief Justice stating they had reconciled and wished to have the cases dismissed. However, the Supreme Court referred the consolidated cases to the Executive Judge of the RTC of Naga City for investigation. The investigating judges faced difficulties as Perpetua Socorro M. De Leoz had applied for optional retirement and moved to the United States, making it impossible to thoroughly investigate the charges against her. Despite these challenges, the investigation continued, focusing on the allegations against Atty. Vargas and Pimentel. Executive Judge Jose T. Atienza concluded that Pimentel had indeed falsified her DTRs and that Atty. Vargas had abetted this falsification. He recommended that both Atty. Vargas and Pimentel be dismissed from the service.

The Supreme Court, after reviewing the findings, agreed that Pimentel and Atty. Vargas were culpable for dishonesty and falsification of official documents. The Court emphasized that substantial evidence supported the conclusion that Pimentel did not regularly report for work from April to August 1994, yet she submitted DTRs indicating her presence. Judge Jose R. Panday testified that he did not assign any research work to Pimentel during this period because she was reviewing for the Bar Examinations. Pimentel’s defense that she was doing research work at the University of Nueva Caceres was deemed unsubstantiated. The Court found that Pimentel’s submission of falsified DTRs constituted a gross act of dishonesty, revealing a lack of candor and disregard for office rules. This unjust enrichment, by receiving salaries without rendering services, warranted disciplinary action.

As for Atty. Vargas, her signature on the falsified DTRs was considered evidence of her role in the acts of dishonesty. By signing the DTRs, she attested to their truthfulness despite knowing they were false. The Court found that Atty. Vargas not only tolerated the dishonesty but also abetted it. Her failure to testify in her defense at the investigative hearings further suggested her culpability. The Court emphasized that the judiciary adheres strictly to the policy of promoting a high standard of ethics in public service. As Clerk of Court, Atty. Vargas had a duty to ensure the accuracy of the DTRs submitted to the Supreme Court. Her failure to uphold this duty and her involvement in the falsification warranted disciplinary action.

Considering the gravity of the offenses, the Supreme Court differed with the OCA’s recommendation of suspension and determined that dismissal from service was the appropriate penalty for both Pimentel and Atty. Vargas. The Court highlighted that falsification of official documents is a grave offense punishable by dismissal, even for the first offense, under Section 23(a) and (f) of the Omnibus Rules and Regulations Implementing Book V of Executive Order No. 292. The Court concluded that it had no option but to apply the law, which called for dismissal in cases of dishonesty and falsification of official documents. Therefore, the Supreme Court found Atty. Amelia B. Vargas and Melinda F. Pimentel guilty of dishonesty and falsification of official documents and ordered their dismissal from service, with forfeiture of all benefits except accrued leave credits and with prejudice to reemployment in the government.

FAQs

What was the key issue in this case?	The key issue was whether court employees were guilty of dishonesty and falsification of official documents by falsifying Daily Time Records (DTRs).
Who were the main parties involved?	The main parties involved were Melinda F. Pimentel, a Legal Researcher, and Atty. Amelia B. Vargas, the Branch Clerk of Court, along with Perpetua Socorro M. De Leoz, a court stenographer.
What did Melinda F. Pimentel and Atty. Amelia B. Vargas do wrong?	Melinda F. Pimentel was found to have falsified her DTRs to make it appear she was working when she was not, and Atty. Amelia B. Vargas abetted this by signing and verifying the false DTRs.
What evidence was presented against Pimentel and Vargas?	Evidence included testimony from colleagues, the lack of leave applications, and the Chief of the Leave Division’s attestation that Pimentel submitted DTRs for the period in question.
What was the Supreme Court’s ruling?	The Supreme Court found Pimentel and Vargas guilty of dishonesty and falsification of official documents and ordered their dismissal from service.
Why was the penalty of dismissal imposed?	The penalty of dismissal was imposed because falsification of official documents and dishonesty are grave offenses under the Omnibus Rules and Regulations Implementing Book V of Executive Order No. 292.
What happened to the cases involving Perpetua Socorro M. De Leoz?	The cases involving Perpetua Socorro M. De Leoz were dismissed due to her residing abroad and the lack of substantial evidence to support the charges against her.
What is the significance of this ruling?	This ruling emphasizes the high ethical standards required of public servants, especially those in the judiciary, and the severe consequences for dishonesty and falsification of official documents.

This case serves as a stark reminder of the importance of honesty and integrity in public service. The Supreme Court’s decision underscores its commitment to maintaining the public’s trust in the judiciary and ensuring that those who violate this trust are held accountable. The dismissal of Pimentel and Vargas sends a clear message that such behavior will not be tolerated, and that the Court will act decisively to uphold ethical standards.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: MELINDA F. PIMENTEL VS. PERPETUA SOCORRO M. DE LEOZ, A.M. No. P-02-1620, April 01, 2003