The Supreme Court affirmed the dismissal of a court stenographer who misrepresented her civil service eligibility by allowing another person to take the Career Service Professional Examination on her behalf. This decision underscores the high standard of honesty and integrity required of all public servants, particularly those in the judiciary. Misrepresenting qualifications to gain employment benefits is a grave offense that undermines the integrity of public service. This ruling reinforces that any form of dishonesty in acquiring or using civil service eligibility is grounds for dismissal and impacts future government employment opportunities.

The Impersonation Puzzle: Can a Civil Servant’s Eligibility be a Facade?

Jovilyn B. Dawang, a court stenographer, was charged with serious dishonesty by the Civil Service Commission (CSC). The CSC alleged that Dawang had someone else take the Career Service Professional Examination in her place in 1996. This came to light when Dawang sought to authenticate her Certificate of Eligibility, revealing discrepancies between the photographs and signatures on her documents. The central question before the Supreme Court was whether Dawang’s actions warranted dismissal from public service, given the gravity of the dishonesty involved.

The Civil Service Commission presented evidence showing significant differences in the facial features between the person in the picture-seat plan for the examination and the photographs Dawang submitted with her Personal Data Sheets. The CSC argued that this discrepancy proved Dawang had used an impersonator to take the exam. Dawang claimed she was a victim of an unscrupulous lawyer-employee of the CSC who assured her of passing the exam without actually taking it. However, the court found her explanation unconvincing, particularly given her subsequent actions.

The Supreme Court emphasized that even if Dawang’s version of events were true, her conduct after receiving the eligibility certificate demonstrated dishonesty. Upon receiving the letter and certificate, Dawang never questioned how she could have passed the examination without taking it. Instead, she used the eligibility to secure a permanent position. This, according to the court, showed a clear intent to deceive and benefit from a fraudulent qualification. The Supreme Court relies on the definition of dishonesty as the:

“disposition to lie, cheat, deceive, or defraud; untrustworthiness; lack of integrity; lack of honesty, probity or integrity in principle; lack of fairness and straightforwardness; disposition to defraud, deceive or betray.”^[40]

Dawang’s Personal Data Sheet further solidified the evidence against her. In it, she falsely stated that she had passed the Career Service Professional Examination, including details such as the date, rating, and place of examination. Despite admitting she never took the exam, she declared under oath that she did. The court viewed this as a deliberate act of dishonesty, undermining the integrity of the civil service system.

The court addressed Dawang’s defense that she did not conspire with anyone, placing the blame solely on the alleged lawyer-employee. However, the court found that regardless of whether there was a conspiracy, Dawang’s act of writing false information on her Personal Data Sheet constituted dishonesty. Her awareness of the requirement to pass an actual examination and her subsequent use of the ill-gotten eligibility demonstrated a disregard for the rules and a lack of integrity.

The Supreme Court referenced the case of Civil Service Commission v. Dasco,^[41] which involved similar facts. In Dasco, a court stenographer was also dismissed for misrepresenting that she took the Career Service Professional Examination. The court reiterated the importance of maintaining integrity within the judiciary, stating that:

Every employee of the judiciary should be an example of integrity, uprightness and honesty. Like any public servant, he must exhibit the highest sense of honesty and integrity not only in the performance of his official duties but in his personal and private dealings with other people, to preserve the court’s good name and standing.^[43]

The Revised Rules on Administrative Cases in the Civil Service, Rule 10, Section 46, classify serious dishonesty as a grave offense punishable by dismissal from the service. Given the gravity of Dawang’s actions, the Supreme Court upheld the recommendation of the Office of the Court Administrator and ordered her dismissal.

This case serves as a reminder that honesty and integrity are paramount in public service. Any act of dishonesty, no matter how small it may seem, can have serious consequences. The Supreme Court’s decision sends a clear message that those who attempt to deceive the government or misrepresent their qualifications will be held accountable.

FAQs

What was the key issue in this case?	The key issue was whether Jovilyn B. Dawang should be dismissed from her position as a court stenographer for serious dishonesty due to misrepresenting her civil service eligibility. The Civil Service Commission found that she had allowed someone else to take the Career Service Professional Examination on her behalf.
What evidence did the Civil Service Commission present against Dawang?	The Civil Service Commission presented evidence showing discrepancies between the photographs on Dawang’s Personal Data Sheets and the picture-seat plan from the Career Service Professional Examination, suggesting she had used an impersonator. They also noted differences in the signatures on the documents.
What was Dawang’s defense?	Dawang claimed she was a victim of an unscrupulous lawyer-employee of the Civil Service Commission who assured her she would pass the exam without actually taking it. She argued she did not conspire with anyone.
What did the Supreme Court say about Dawang’s defense?	The Supreme Court found her explanation unconvincing, stating that even if her version of events were true, her actions after receiving the eligibility certificate demonstrated dishonesty. Specifically, they noted she never questioned how she could have passed without taking the exam and used the eligibility to secure a permanent position.
What is the penalty for serious dishonesty in the civil service?	Under the Revised Rules on Administrative Cases in the Civil Service, Rule 10, Section 46, serious dishonesty is a grave offense punishable by dismissal from the service.
What was the Supreme Court’s ruling in this case?	The Supreme Court ruled to dismiss Jovilyn B. Dawang from service with forfeiture of all retirement benefits except her accrued leave credits, and with prejudice to re-employment in any branch or instrumentality of the government, including government-owned or controlled corporations.
Why did the Supreme Court emphasize the importance of honesty in the judiciary?	The Supreme Court emphasized that every employee of the judiciary should be an example of integrity, uprightness, and honesty. Like any public servant, they must exhibit the highest sense of honesty and integrity to preserve the court’s good name and standing.
What was the significance of the Civil Service Commission v. Dasco case?	The Civil Service Commission v. Dasco case was cited as a similar instance where a court stenographer was dismissed for misrepresenting that she took the Career Service Professional Examination. It reinforced the principle that such dishonesty warrants dismissal.
What constitutes dishonesty?	Dishonesty is the disposition to lie, cheat, deceive, or defraud; untrustworthiness; lack of integrity; lack of honesty, probity or integrity in principle; lack of fairness and straightforwardness; disposition to defraud, deceive or betray.

This case illustrates the severe consequences of dishonesty in the civil service. It highlights the importance of upholding integrity in public office and reinforces the principle that any form of misrepresentation to gain employment benefits will not be tolerated. Public servants must adhere to the highest ethical standards to maintain the public’s trust and confidence in the government.

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 v. DAWANG, A.M. No. P-15-3289, February 17, 2015