The Supreme Court affirmed the dismissal of Ismael A. Hadji Ali, a Court Stenographer I, for dishonesty related to a civil service examination. The Court found substantial evidence that someone else took the exam on his behalf. This ruling emphasizes the high standard of integrity required of those in the judiciary and the severe consequences for those who fail to meet it. The decision reinforces the importance of honesty and ethical conduct in public service, particularly within the judicial branch, and serves as a warning against any form of deceit or misrepresentation.

When a False Test Leads to a Failed Career: The Case of Ismael A. Hadji Ali

This case revolves around Ismael A. Hadji Ali, a Court Stenographer I at the Shari’a Circuit Court of Tubod, Lanao del Norte. His career took a downturn when the Civil Service Commission (CSC) discovered discrepancies in his civil service eligibility. Suspicions arose concerning the Career Service Professional Examination he claimed to have passed in 2000. The CSC’s investigation revealed that the person who took the exam was not Hadji Ali.

The CSC initiated a formal charge of dishonesty against Hadji Ali. According to the formal charge:

That you (true Ismael A. Hadji Ali), knowingly and unlawfully allowed somebody else to take the 11 May 2000 Career Service Examination (Professional) through the Computer-Assisted Test given in Zamboanga City, for and in your behalf, as shown in the attached machine copies of the Picture Seat Plan used during the aforesaid examination and your Personal Data Sheet accomplished on 22 February 2000.

The case eventually reached the Supreme Court after being processed through the Office of the Court Administrator (OCA). The central issue was whether Hadji Ali had indeed committed dishonesty by allowing another person to take the civil service examination in his place. The resolution of this issue would determine his fate as a public servant.

Hadji Ali denied the allegations, asserting that he personally took the examination and passed with a score of 86.76%. He suggested that his photograph on the Picture Seat Plan might have been replaced. He also argued that the CSC was estopped from questioning his eligibility because they had already approved his appointment. However, the Court was not persuaded by his arguments.

The Court referred the case to the Executive Judge of the Regional Trial Court of Zamboanga City for investigation. Despite being notified, Hadji Ali did not attend the hearings. The investigating judge found substantial evidence supporting the charge of dishonesty. The judge noted significant differences between Hadji Ali’s photograph and signature on his Personal Data Sheet and the Picture Seat Plan.

The Executive Judge stated:

It is clear that the picture of the person and signature appearing on the Picture Seat Plan (Exhibit “A,” Rollo, p. 35) do not resemble the picture and signature of the respondent as appearing in his Personal Data Sheet (Exhibit “B” and “B-3,” Rollo, pp. 36-37). And the respondent does not really dispute this fact more so, in light of his allegation and which respondent would want us to believe that the picture pasted on the Picture Seat Plan must have been replaced by someone who wanted him removed.

The Court also cited the case of *Cruz and Paitim v. CSC*, which highlights the strict procedures followed during civil service examinations.

It should be stressed that as a matter of procedure, the room examiners assigned to supervise the conduct of a Civil Service examination closely examine the picture submitted and affixed on the Picture Seat Plan (CSC Resolution No. 95-3694, Obedencio, Jaime A.) The examiners carefully compare the appearance of each of the examinees with the person in the picture submitted and affixed on the PSP. In cases where the examinee does not look like the person in the picture submitted and attached on the PSP, the examiner will not allow the said person to take the examination (CSC Resolution No. 95-5195, Taguinay, Ma. Theresa).

The OCA also agreed with the investigating judge’s findings. The Supreme Court then adopted the recommendation to dismiss Hadji Ali from service.

The Court emphasized that the differences between Hadji Ali’s identification photos and signatures strongly suggested that another person took the examination for him. His claim that his photo was replaced lacked evidence and persuasive weight. The Court found no reason to believe that unknown persons would interfere with his civil service eligibility.

The Court referred to *Civil Service Commission v. Zenaida T. Sta. Ana*, a similar case where a court stenographer was dismissed for dishonesty after someone else took the civil service exam for her. The Court in that case also rejected the explanation that an unknown person had replaced her photo.

The Supreme Court reiterated the grave nature of dishonesty, especially within the judiciary. The Court emphasized the high standards of moral righteousness required of judiciary employees.

According to CSC Memorandum Circular No. 15, Series of 1991, the use of spurious civil service eligibility constitutes dishonesty. The Court underscored that dishonesty is a grave offense punishable by dismissal. It carries accessory penalties, including cancellation of eligibility, forfeiture of retirement benefits, and disqualification from re-employment in the government service.

FAQs

What was the key issue in this case?	The central issue was whether Ismael A. Hadji Ali committed dishonesty by allowing someone else to take the civil service exam on his behalf, thereby impacting his position as a Court Stenographer.
What evidence did the Court consider?	The Court considered the discrepancies between Hadji Ali’s photos and signatures on his Personal Data Sheet and the Picture Seat Plan, along with the testimony of CSC officials and the investigating judge’s report.
What was Hadji Ali’s defense?	Hadji Ali claimed he took the exam himself and that his photo on the Picture Seat Plan was replaced, but he failed to provide evidence to support this claim.
Why was Hadji Ali dismissed?	He was dismissed due to dishonesty. The Court found that he allowed another person to take the civil service exam for him, which is a grave offense.
What are the consequences of dismissal for dishonesty?	The consequences include forfeiture of retirement benefits (except accrued leave credits), cancellation of eligibility, and disqualification from re-employment in government service.
How does this case relate to other similar cases?	The Court cited *Civil Service Commission v. Zenaida T. Sta. Ana* as a similar case where a court employee was dismissed for a similar act of dishonesty.
What standard of conduct is expected of judiciary employees?	The Court emphasized that a high standard of moral righteousness is expected of employees in the judiciary, and dishonesty is not tolerated.
What does CSC Memorandum Circular No. 15 say about spurious eligibility?	It states that the use of fake civil service eligibility is considered a grave offense of dishonesty, among other violations.
What was the role of the Office of the Court Administrator (OCA) in this case?	The OCA reviewed the report and recommendation of the investigating judge and agreed with the findings before the case reached the Supreme Court.

This case reaffirms the importance of integrity and honesty in public service, particularly within the judiciary. The Supreme Court’s decision serves as a strong deterrent against fraudulent activities related to civil service examinations, emphasizing that such actions will be met with severe consequences.

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: CIVIL SERVICE COMMISSION vs. ISMAEL A. HADJI ALI, G.R. No. 55898, June 18, 2013