The Supreme Court in this case affirmed the dismissal of a court employee for falsifying official documents, specifically her Daily Time Records (DTRs). This ruling underscores the high standard of integrity required of all judiciary employees, reinforcing that any act of dishonesty, such as tampering with official records, will be met with severe consequences, including dismissal from service and forfeiture of benefits. The decision emphasizes the critical importance of maintaining accurate and truthful records within the judiciary, as the integrity of these records directly impacts public trust and confidence in the justice system.

Time Tampering in the Judiciary: Can False Records Lead to True Dismissal?

This case originated from a report by Clerk of Court Eleonor T.F. Marbas-Vizcarra regarding tampered Daily Time Records (DTRs) of several employees at the Regional Trial Court (RTC) Branch 30 in Cabanatuan City. The investigation revealed that Ma. Dina A. Bernardo, a Clerk III, and Gregoria R. Florendo, a Court Interpreter, were responsible for altering these records. The tampering was discovered following letters from Atty. Adelaida Cabe-Baumann of the Supreme Court, which highlighted discrepancies in the DTRs submitted.

Atty. Vizcarra’s investigation uncovered that Florendo and Bernardo had tampered with their own DTRs and those of other employees without their consent. According to statements from involved personnel, the falsification aimed to conceal absences, thereby avoiding salary deductions. This scheme unraveled when other employees refused to support the falsehood and provided truthful accounts of the tampering. Furthermore, the initial investigation revealed that Ms. Florendo, in a meeting, admitted, “kung yung amin lang ang tatamperin namin baka hindi ka mag-second thought na ireport kami, ngayon maraming DTR ang tampered baka sakaling hindi mo kami ireport at marami kami.”

The Court emphasized that falsification of official documents is a grave offense under Section 22(f) of the Omnibus Civil Service Rules and Regulations, warranting dismissal even for the first offense. The Court has consistently held that employees in the judiciary must maintain the highest standards of conduct, both on and off duty. Their behavior must be beyond reproach to maintain public trust in the judicial system. In this instance, the actions of Ms. Bernardo clearly undermined the integrity expected of a court employee.

Following the initial inquiry, the Court directed Executive Judge Johnson L. Ballutay of the RTC, Cabanatuan City, to conduct an investigation. Judge Ballutay’s report validated Atty. Vizcarra’s findings, confirming the involvement of Bernardo and Florendo in the tampering of DTRs. During the proceedings, Bernardo tendered her resignation, which the Court did not accept, opting instead to pursue the administrative case against her. In a related case, Vizcarra vs. Florendo, Florendo was dismissed from service, while Bernardo was not initially charged but was later included as a respondent after further investigation.

Despite being notified of the charges against her, Bernardo failed to submit a comment or appear before the investigating judge. This non-compliance further strengthened the case against her. The Investigating Judge, Johnson L. Ballutay, recommended the dismissal of Bernardo from service. The Court agrees with the recommendation of the Investigating Judge as the evidence presented, coupled with the respondent’s failure to controvert said charges, coupled with her tendering resignation pending the outcome of the administrative case are all indications of her culpability. The actions of the respondent constitute acts of falsification.

The Court reiterated that the conduct of those involved in the administration of justice, from judges to clerks, must be “characterized by propriety and decorum and be beyond suspicion.” Any act that violates public accountability or undermines faith in the judiciary cannot be tolerated. Due to the gravity of the offense and the respondent’s failure to follow court procedure in rebutting the evidence against her, the Court ruled in favor of dismissing Ms. Bernardo.

The Court emphasized the importance of honesty and integrity in public service. By falsifying official records, Bernardo not only violated civil service rules but also compromised the integrity of the judiciary. The decision serves as a stern warning to all court employees: acts of dishonesty will be dealt with severely, ensuring that the judiciary remains a pillar of justice and integrity.

FAQs

What was the key issue in this case?	The key issue was whether Ma. Dina A. Bernardo should be dismissed from service for falsifying official documents, specifically her Daily Time Records (DTRs). The Supreme Court addressed whether such actions warranted the penalty of dismissal.
What specific actions did Ma. Dina A. Bernardo take?	Ma. Dina A. Bernardo tampered with her own DTRs and those of other employees without their knowledge or consent. This involved altering the records to conceal absences and avoid salary deductions.
What rule did Ma. Dina A. Bernardo violate?	Ma. Dina A. Bernardo violated Section 22(f) of the Omnibus Civil Service Rules and Regulations, which classifies falsification of official documents as a grave offense. This offense is punishable by dismissal from service, even for the first offense.
What was the basis for the Supreme Court’s decision to dismiss Ma. Dina A. Bernardo?	The Supreme Court based its decision on the evidence presented, Bernardo’s failure to appear before the investigating judge, and her act of tendering her resignation while facing administrative charges. These factors collectively pointed to her guilt.
Why was the integrity of court employees so important in this case?	The Court stressed that individuals involved in administering justice must be characterized by propriety and decorum, and their conduct should be beyond suspicion. Public accountability and faith in the judiciary depend on this integrity.
What happened to Gregoria R. Florendo, the other employee involved in the tampering?	Gregoria R. Florendo was also found guilty of falsifying DTRs and was dismissed from the service with forfeiture of all benefits and accrued leave credits. She was also barred from reemployment in the government.
What message did this Supreme Court decision convey to other court employees?	The decision conveyed a strong message that dishonesty and falsification of official documents will not be tolerated. It emphasized the importance of maintaining accurate and truthful records and upholding public trust in the judiciary.
What is the effect of dismissing an employee with forfeiture of all benefits and accrued leave credits?	Dismissal with forfeiture means the employee loses all retirement benefits, leave credits, and other entitlements they have accumulated during their employment. Additionally, they are disqualified from being rehired in any government position.

In conclusion, the Supreme Court’s decision underscores the non-negotiable principle of honesty and integrity within the Philippine judiciary. This ruling reinforces the message that any act compromising the integrity of official records will be met with the full force of the law, safeguarding public trust and maintaining the sanctity of the justice system.

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: Clerk of Court Eleonor T. F. Marbas-Vizcarra vs. Ma. Dina A. Bernardo, A.M. No. P-99-1336, February 06, 2001