In Civil Service Commission v. Cayobit, the Supreme Court addressed the issue of dishonesty within the public sector, specifically the use of a falsified civil service eligibility certificate. The Court reversed the Court of Appeals’ decision, finding Evelyn P. Cayobit guilty of dishonesty and grave misconduct. This decision underscores the importance of maintaining integrity in public service and reinforces the authority of the Civil Service Commission (CSC) to safeguard the integrity of civil service examinations. The ruling demonstrates that any misrepresentation or falsification of documents to gain advantage in government employment is a grave offense with serious consequences.

Forged Credentials, Tarnished Career: Can a Falsified Eligibility Certificate Lead to Dismissal?

Evelyn P. Cayobit, an employee of the National Housing Authority (NHA), submitted a certificate of eligibility indicating she passed the civil service examination with a rating of 81.20%. This certificate played a role in her appointment as a Senior Livelihood Officer, a position requiring civil service eligibility. However, the Civil Service Commission (CSC) discovered that Cayobit had actually failed the examination, obtaining a score of only 40.96%. Consequently, she was charged with dishonesty and grave misconduct.

The CSC based its findings on the **masterlist of eligibles**, the official record of examination results. This list, maintained by the CSC, revealed the discrepancy between Cayobit’s claimed passing grade and her actual failing grade. The central question before the Supreme Court was whether the masterlist of eligibles or the certificate of eligibility should be considered the primary record for determining civil service eligibility.

The Supreme Court firmly established that the masterlist of eligibles is the primary record of civil service eligibility. The Court emphasized the Civil Service Commission’s constitutional and statutory mandate to conduct and safeguard civil service examinations. Executive Order No. 292, also known as the Administrative Code of 1987, mandates the CSC to maintain a register of eligibles.

Sec. 24. Register of Eligibles.– The names of the competitors who pass an examination shall be entered in a register of eligibles arranged in the order of their general ratings and containing such information as the Commission may deem necessary.

The masterlist is the official record used by the CSC to verify the eligibility of applicants for government service, ensuring accuracy and preventing fraudulent claims. By upholding the masterlist as the primary source of verification, the Court reinforced the CSC’s role in upholding the integrity of government appointments. Allowing certificates to be the sole basis for eligibility verification would undermine the CSC’s oversight and create opportunities for fraudulent practices.

Having established the primacy of the masterlist, the Supreme Court addressed whether substantial evidence existed to prove that Cayobit knowingly used a fake or spurious certificate of eligibility. The Court highlighted that dishonesty, defined as the concealment or distortion of truth relevant to one’s office, is a grave offense. Using a fake civil service eligibility falls squarely within this definition. CSC Memorandum Circular No. 15, Series of 1991, explicitly categorizes the procurement or use of fake civil service eligibility as dishonesty and grave misconduct, punishable by dismissal.

An act which includes the procurement and/or use of fake/spurious civil service eligibility, the giving of assistance to ensure the commission or procurement of the same, cheating, collusion, impersonation, or any other anomalous act which amounts to any violation of the Civil Service examination, has been categorized as a grave offense of Dishonesty, Grave Misconduct or Conduct Prejudicial to the Best Interest of the Service.

The Court found that the discrepancy between Cayobit’s claimed passing grade and her actual failing grade in the masterlist constituted substantial evidence of her guilt. The court deemed her explanation that she received the certificate by mail and believed it to be genuine as unconvincing, pointing out that she failed to present any evidence that the error was on the CSC’s part. Ultimately, the Court found Cayobit guilty of dishonesty and grave misconduct.

The Supreme Court underscored that in administrative proceedings, only substantial evidence is required, which means relevant evidence a reasonable mind might accept as adequate to support a conclusion. This standard was met by the discrepancy in Cayobit’s grades. Thus, the Court ruled in favor of the Civil Service Commission, dismissing Cayobit from service and imposing accessory penalties, including perpetual disqualification from taking civil service examinations and holding public office. This case sends a clear message about the consequences of dishonesty and the importance of maintaining integrity in public service.

FAQs

What was the key issue in this case?	The central issue was whether the masterlist of eligibles or the certificate of eligibility should be considered the primary record for verifying civil service eligibility. The Supreme Court ruled that the masterlist is the primary record.
What did the Civil Service Commission charge Evelyn Cayobit with?	The Civil Service Commission charged Evelyn Cayobit with dishonesty and grave misconduct for submitting a falsified certificate of eligibility. This was in support of her appointment as Senior Livelihood Officer at the National Housing Authority.
What evidence did the Civil Service Commission use against Cayobit?	The Civil Service Commission used the masterlist of eligibles, which showed that Cayobit failed the civil service examination, contradicting the passing grade on her submitted certificate. This discrepancy was used to establish dishonesty.
What was the Court of Appeals’ initial decision in the case?	The Court of Appeals initially granted Cayobit’s petition and nullified the Civil Service Commission’s resolution, finding that there was no substantial evidence to prove she committed the offenses charged. This decision was later reversed by the Supreme Court.
What is the significance of the “masterlist of eligibles”?	The “masterlist of eligibles” is the official record maintained by the Civil Service Commission that lists all examinees who passed and failed a given civil service examination. It’s used to verify the eligibility of applicants for government service.
What penalty did Evelyn Cayobit receive?	Evelyn Cayobit was dismissed from service and perpetually disqualified from taking any civil service examination and holding public office. This reflects the gravity of the offense.
What constitutes “substantial evidence” in administrative cases?	In administrative cases, substantial evidence refers to relevant evidence that a reasonable mind might accept as adequate to support a conclusion. It is less stringent than the evidence required in criminal cases.
What is the definition of “dishonesty” in the context of public service?	“Dishonesty” in public service is defined as the concealment or distortion of truth in a matter of fact relevant to one’s office or connected with the performance of one’s duty. It is a grave offense.
Does CSC Memorandum Circular No. 15 series of 1991 say about fake Civil Service eligibility?	CSC Memorandum Circular No. 15, Series of 1991 specifically lists that procurement and/or use of fake/spurious civil service eligibility, the giving of assistance to ensure the commission or procurement of the same are grave offenses of Dishonesty, Grave Misconduct or Conduct Prejudicial to the Best Interest of the Service.

The Supreme Court’s decision in Civil Service Commission v. Cayobit underscores the critical importance of honesty and integrity within the Philippine civil service. It clarifies that the Civil Service Commission’s masterlist of eligibles is the primary document for verifying the qualifications of individuals seeking government positions, reinforcing the CSC’s role as a gatekeeper against fraud and misrepresentation in government hiring.

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. EVELYN P. CAYOBIT, G.R. No. 145737, September 03, 2003