The Supreme Court, in this case, firmly established that dishonesty and grave misconduct, particularly the falsification of Daily Time Records (DTRs), warrant dismissal from service for judiciary employees. This ruling underscores the high standards of integrity and honesty expected of public servants, especially those within the judicial system. The Court emphasized that falsifying time records is a severe breach of trust that undermines public confidence in the judiciary, leading to the dismissal of the respondent, a Clerk III, with forfeiture of benefits and disqualification from future government employment. This decision reinforces the principle that public office is a public trust, demanding strict adherence to ethical standards and faithful performance of duties.

Time Sheet Treachery: Can a Court Employee’s Deceitful Record-Keeping Justify Dismissal?

This case revolves around Lourdes S. de Mateo, a Clerk III at the Municipal Trial Court in Cities (MTCC) of Koronadal City, South Cotabato, who faced allegations of falsifying her Daily Time Records (DTRs), along with charges of dishonesty and grave misconduct. The anonymous letter-complaints detailed how de Mateo habitually reported late for work but recorded her arrival as 8:00 a.m. in her DTR, effectively concealing her tardiness and absences. Further accusations included her alleged involvement in ‘fixing’ activities within the Hall of Justice, associating with known ‘fixers,’ and participating in the falsification of a bail bond document. These allegations prompted an investigation to determine the extent of de Mateo’s culpability and the appropriate disciplinary action.

Upon investigation, Regional Trial Court Judge Oscar E. Dinopol found de Mateo liable for grave misconduct and falsification. The investigation revealed discrepancies between de Mateo’s DTR entries and the logs maintained by the Head Guard, who recorded her actual arrival and departure times upon instruction from Executive Judge Francisco S. Ampig, Jr. The Office of the Court Administrator (OCA) concluded that de Mateo had indeed initiated and consented to the falsification of her DTR, particularly for the period of October 11 to 25, 1999. During this time, her usual tardiness and absences were not reflected in her DTR, and there were instances when her DTR card was punched in by her fellow employees. The OCA recommended her dismissal from service due to dishonesty and grave misconduct.

The Supreme Court noted that de Mateo failed to provide a satisfactory explanation for the discrepancies between her DTR entries and the Head Guard’s logs. The Court gave credence to the Head Guard’s records, finding no apparent reason for him to falsify these entries. Additionally, the Court acknowledged the OCA report, which highlighted that the Clerk of Court, not the Judge, is responsible for certifying the correctness of DTR entries. The Court also considered de Mateo’s alleged participation in the falsification of a bail bond document, referencing the sworn statement of Lydia Jayme, who detailed how the falsifications were carried out. The OCA also presented supporting evidence, including falsified tax declarations and a handwritten note from de Mateo to Nita Frias, indicating her awareness of the questioned bail bonds and her request to expedite their processing.

However, the Supreme Court emphasized the importance of substantial evidence in administrative proceedings, stating that the complainant bears the burden of proving the allegations by such evidence. The Court found that the evidence relied upon by Judge Dinopol did not conclusively demonstrate that de Mateo had a direct hand in the falsification of the bail bond documents. Specifically, the sworn statement of Lydia Jayme lacked corroboration and was not presented during the hearings. The handwritten note from de Mateo to Nita Frias was neither authenticated nor supported by any witness. Moreover, the documents supporting the bail bond application, on their own, did not establish falsification without further credible witness testimony. Despite these evidentiary concerns regarding the bail bond falsification, the Court focused on the falsification of the DTR.

Addressing the imposable penalty, the Supreme Court affirmed that falsification of daily time records constitutes patent dishonesty. The Court defined dishonesty as a “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.” The Court cited precedents emphasizing that dishonesty, as a grave offense, warrants dismissal from service, forfeiture of retirement benefits (except accrued leave credits), and perpetual disqualification from re-employment in government service. Finding that de Mateo provided no satisfactory explanation for the charges of dishonesty against her and lacking any mitigating circumstances, the Court upheld the OCA’s recommendation of dismissal as appropriate.

The Court emphasized that de Mateo failed to uphold the standards of honesty and integrity required of public servants. The Court reiterated that public office is a public trust, which includes observing prescribed office hours and utilizing them efficiently for public service. The ruling cited Re: Administrative Case for Dishonesty Against Elizabeth Ting, Court Sec. I & Angelita C. Esmerio, Clerk III, Off. Clerk of Court, A.M. No. 2001-7-SC & No. 2001-8-SC, July 22, 2005, 464 SCRA 1, 16, underscoring that punctuality is a virtue, while absenteeism and tardiness are impermissible. The Supreme Court asserted its duty to discipline errant employees and remove those found undesirable to maintain public confidence and respect for the justice system. Any act or omission by a court employee that violates public accountability and diminishes faith in the Judiciary cannot be countenanced.

FAQs

What was the key issue in this case?	The key issue was whether Lourdes S. de Mateo, a Clerk III, should be dismissed from service for falsifying her Daily Time Records (DTRs) and for grave misconduct. The Supreme Court focused on the dishonesty demonstrated by the falsification of the DTRs.
What is a Daily Time Record (DTR)?	A Daily Time Record (DTR) is an official document used by government employees to record their daily attendance, including arrival and departure times. It serves as a basis for calculating their salaries and ensuring compliance with prescribed office hours.
What constitutes dishonesty in the context of public service?	Dishonesty in public service involves acts of lying, cheating, deceiving, or defrauding, demonstrating untrustworthiness and a lack of integrity. It includes any conduct that betrays the public trust and undermines the principles of fairness and honesty.
What is the penalty for dishonesty in the Philippine Judiciary?	The penalty for dishonesty, being a grave offense, is dismissal from the service, forfeiture of retirement benefits (except accrued leave credits), and perpetual disqualification from re-employment in government service. This reflects the zero-tolerance policy for dishonesty within the Judiciary.
What is grave misconduct?	Grave misconduct involves actions that, although not criminal, constitute a serious breach of the standards of conduct expected of a public official. It typically includes elements such as corruption, willful intent to violate the law, or a flagrant disregard for established rules.
What is the role of the Office of the Court Administrator (OCA) in administrative cases?	The Office of the Court Administrator (OCA) is responsible for the supervision and administration of all courts in the Philippines. In administrative cases, the OCA investigates complaints against court personnel, evaluates evidence, and recommends appropriate disciplinary actions to the Supreme Court.
What kind of evidence is required to prove an administrative case?	Substantial evidence is required to prove an administrative case. This means that there must be relevant evidence that a reasonable mind might accept as adequate to justify a conclusion that the employee committed the alleged offense.
Why is honesty and integrity important for court employees?	Honesty and integrity are crucial for court employees because they are essential to maintaining public trust and confidence in the justice system. Any act of dishonesty or misconduct can erode this trust and undermine the Judiciary’s ability to administer justice fairly and impartially.

In conclusion, this Supreme Court decision serves as a stern reminder to all public servants, particularly those in the Judiciary, of the paramount importance of honesty, integrity, and adherence to ethical standards. The falsification of official records and other acts of misconduct will not be tolerated, and those who violate these principles will face severe consequences, including dismissal from service. The ruling underscores the commitment of the Philippine justice system to uphold the highest standards of public accountability and maintain public trust.

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: A Very Concerned Employee and Citizen vs. Lourdes S. De Mateo, A.M. No. P-05-2100, December 27, 2007