The Supreme Court held that falsification of a Daily Time Record (DTR) by a court employee constitutes a grave offense, specifically falsification of an official document and dishonesty. Even if the employee has resigned, the Court retains the authority to impose penalties, including forfeiture of retirement benefits and disqualification from government service. This decision underscores the high standards of integrity and accountability expected of public servants and reinforces the principle that public office is a public trust.

When a Time Sheet Tells a Tale: Accountability in the Judiciary

This case arose from discrepancies found in the Daily Time Record (DTR) of Jaime P. Kasilag, a Sheriff IV at the Regional Trial Court (RTC) of Manila, Branch 27. The Office of the Court Administrator (OCA) initiated an investigation after noticing apparent “superimpositions” on Kasilag’s DTR for February 2004. These markings suggested that Kasilag had altered his attendance record to falsely reflect that he had worked on days when he was actually on leave. The RTC’s Officer-in-Charge, Victor Y. Serapio, confirmed these discrepancies, noting that Kasilag’s DTR did not match the RTC’s Daily Time Registry Book. This led to a recommendation for disciplinary action against Kasilag, setting in motion a series of legal proceedings that ultimately reached the Supreme Court.

Despite being directed multiple times to submit a comment and explain the discrepancies in his DTR, Kasilag repeatedly failed to do so. This prompted the Court to issue a Show Cause Order, demanding an explanation for his refusal to cooperate. Instead of complying, Kasilag filed a Motion for Reconsideration, arguing that his delay was unintentional and due to his inability to recall the events and a lack of access to the relevant documents. The Supreme Court, however, found his reasons unconvincing and highlighted that Kasilag had ample opportunity to seek the documents he claimed were missing. Even after his resignation in 2007, the Court maintained its jurisdiction over the administrative case, emphasizing that resignation does not preclude administrative liability.

The Supreme Court emphasized the gravity of falsifying official documents, particularly within the judiciary. Such acts undermine the integrity of public service and erode public trust. The Court referenced Section 52(A)(1) and (6) of the Uniform Rules on Administrative Cases in the Civil Service, which classifies falsification of official documents as a grave offense. The case of Office of the Court Administrator v. Breta, 519 Phil. 106 (2006), was also cited, reinforcing the principle that falsification and dishonesty are grave offenses punishable by dismissal from service, forfeiture of retirement benefits, and perpetual disqualification from reemployment in government service. This consistent application of the law demonstrates the Court’s commitment to upholding the highest standards of conduct among its personnel.

The Court articulated the constitutional basis for demanding accountability from public officers, stating that “Public office is a public trust.” This principle, enshrined in Article XI of the Constitution, requires public officers to be accountable to the people, serve with utmost responsibility, integrity, loyalty, and efficiency, and act with patriotism and justice. The Court emphasized that these standards are not mere ideals but are woven into the fabric of the legal system and must be enforced to bridge the gap between reality and the envisioned norms for public service. In this context, the falsification of a DTR, a seemingly minor act, becomes a significant breach of public trust because it violates the core values of integrity and honesty expected of public servants.

The Supreme Court dismissed any notion that Kasilag’s resignation absolved him of administrative liability. Citing Pagano v. Nazarro, G.R. No. 149072, 21 September 2007, 533 SCRA 622, 628, the Court reiterated that “the resignation of a public servant does not preclude the finding of any administrative liability to which he or she shall still be answerable.” This principle ensures that public servants cannot escape accountability for their actions by simply resigning from their positions. The Court’s decision to proceed with the case despite Kasilag’s resignation underscores its commitment to upholding ethical standards in public service, even when the individual is no longer actively employed by the government.

The Supreme Court found substantial evidence to support the charge that Kasilag had falsified his DTR. The certified copy of the DTR, submitted by the RTC’s Officer-in-Charge, clearly showed superimpositions on Kasilag’s time entries. This evidence, according to the Court, was “relevant evidence which a reasonable mind might accept as adequate to justify [the] conclusion” that Kasilag had indeed falsified his DTR. The Court also noted that Kasilag had been given ample opportunity to present his side of the story but repeatedly failed to do so. His failure to file a comment, despite multiple directives from the Court, was deemed contumacious and a waiver of his right to be heard.

The Supreme Court concluded that Kasilag’s actions constituted both falsification of an official document and dishonesty, offenses that strike at the heart of public accountability. The Court found no mitigating circumstances to excuse Kasilag’s conduct, emphasizing that such acts detract from the notion of public accountability as implemented by law. As a result, the Court ordered the forfeiture of Kasilag’s entire retirement benefits, except for accrued leave credits, and permanently disqualified him from reemployment in any branch or instrumentality of the government, including government-owned and controlled corporations. This ruling sends a strong message that dishonesty and falsification will not be tolerated in public service and will be met with severe consequences.

FAQs

What was the key issue in this case?	The key issue was whether a court sheriff was administratively liable for falsifying his Daily Time Record (DTR), and what penalties could be imposed, even after his resignation.
What is a Daily Time Record (DTR)?	A Daily Time Record (DTR) is an official document used to record the attendance and working hours of government employees. It serves as a basis for payroll and ensures accountability for work performed.
What constitutes falsification of an official document?	Falsification of an official document involves altering or misrepresenting information in a document issued by a government agency or used for official purposes. This can include changing dates, times, or any other material information.
Can a government employee be penalized after resignation?	Yes, the resignation of a government employee does not preclude the finding of administrative liability for offenses committed during their tenure. Penalties such as forfeiture of benefits and disqualification from future employment can still be imposed.
What penalties can be imposed for falsifying a DTR?	Penalties for falsifying a DTR can include dismissal from service, forfeiture of retirement benefits (except accrued leave credits), and perpetual disqualification from reemployment in government service.
What is the basis for holding public officers accountable?	The principle of public accountability is enshrined in Article XI of the Philippine Constitution, which states that public office is a public trust. Public officers must be accountable to the people and serve with integrity, responsibility, and efficiency.
What is the role of the Office of the Court Administrator (OCA)?	The Office of the Court Administrator (OCA) is responsible for the supervision and administration of all courts in the Philippines. It investigates complaints against court personnel and recommends appropriate disciplinary actions.
What does the ruling mean for other government employees?	The ruling serves as a reminder to all government employees of the importance of honesty and integrity in public service. It underscores that falsification of official documents will be met with severe consequences, regardless of whether the employee has resigned.

This case reinforces the judiciary’s commitment to maintaining the highest ethical standards within its ranks. By holding accountable those who violate the public trust, the Supreme Court aims to preserve the integrity of the legal system and ensure that public servants act with honesty and responsibility.

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: OFFICE OF THE COURT ADMINISTRATOR v. JAIME P. KASILAG, A.M. No. P-08-2573, June 19, 2012