G.R. No. A.M. No. 85-1-6874-RTC April 25, 1985
IN RE: MILAGROS SANTIA, Stenographic Reporter, Branch XXX, RTC, Iloilo City

FACTS

Milagros Santia, a stenographic reporter at the Regional Trial Court of Iloilo City, failed to report for duty after her approved leave of absence expired on December 29, 1983. Despite a directive from the Acting Court Administrator dated March 28, 1984, requiring her to explain her prolonged absence without leave, Santia ignored the order and did not return to her post. This prolonged absence was reported by the Acting Executive Judge, who noted it had greatly jeopardized court operations and requested her position be declared vacant.
Further, it was reported that Santia had engaged in serious misconduct. She was alleged to have falsified the signature of Judge Amelia K. del Rosario on a special power of attorney, which she used to unlawfully obtain and endorse the paychecks of judges and court employees for February 1984. Reliable information indicated that criminal charges had been filed against her in connection with this act.

ISSUE

Whether respondent Milagros Santia should be separated from the service for abandonment of office and malfeasance.

RULING

Yes, the Supreme Court ordered Santia’s separation from service. The legal logic rests on two independent and sufficient grounds: abandonment of office and conviction for a crime involving moral turpitude. First, her continuous absence without approved leave since January 1984, coupled with her failure to respond to the official directive to explain, constitutes a clear case of abandonment. Abandonment is a voluntary act of relinquishment, demonstrated by a prolonged, unexplained absence and a clear intent to sever the employer-employee relationship, which her actions unequivocally showed.
Second, and more decisively, the Court took judicial notice of a final conviction against Santia. A decision dated October 29, 1984, from the RTC of Manila, convicted her of seventeen counts of falsification of private documents. Falsification is a crime of moral turpitude, which inherently involves deceit and reflects on the offender’s integrity and fitness to hold public office. A court employee, especially one in a position of trust like a stenographic reporter, must uphold the highest standards of honesty. Her criminal conviction for acts directly related to her official environment (misappropriating payroll) constitutes grave malfeasance. Consequently, the Court imposed the penalty of separation from service with forfeiture of all retirement benefits and with prejudice to future employment in any government agency.