A.M. No. 2003-7-SC; December 15, 2003
Administrative Case for Dishonesty and Falsification of Official Document against Noel V. Luna, SC Chief Judicial Staff Officer, Systems Planning and Project Evaluation (SPPE) Division, MISO

FACTS

This administrative case originated from an anonymous text message referred by the Civil Service Commission (CSC) to the Supreme Court, alleging that respondent Noel V. Luna, a Chief Judicial Staff Officer, falsely claimed to be a college graduate in his Personal Data Sheet (PDS). Investigation revealed that in his PDS dated January 15, 1998, submitted for his promotion to the said permanent position, Luna indicated he obtained a “BS ELECTRICAL ENGINEERING” degree from 1982-1987. Verification from the Lyceum of the Philippines, however, certified that Luna lacked 54 units to complete the degree. The position he applied for and was appointed to in 1998 required a bachelor’s degree as a minimum qualification.
In his defense, Luna admitted he did not possess the degree but denied making the false entry. He claimed he personally typed his PDS and left the educational attainment blank, suggesting the entry was spurious and inserted by another person without his knowledge or authentication. He asserted his lack of a college degree was known to his colleagues and he had no reason to falsify the document.

ISSUE

Whether respondent Noel V. Luna is administratively liable for Dishonesty and Falsification of an Official Document.

RULING

Yes, the Supreme Court En Banc found respondent guilty of both charges and dismissed him from service. The Court rejected Luna’s denial and explanation. His claim that he left the educational background blank was contradicted by the accomplished PDS form itself, which clearly contained the typewritten false entry. The Court emphasized that a public officer is presumed to take care of and review official documents he signs; thus, Luna is responsible for the contents of his own PDS submitted under oath. His failure to verify the entry before submission constituted gross negligence, if not deliberate intent to deceive.
The false declaration of a college degree, a concrete qualification for the permanent position he secured, constituted dishonesty as it was a deliberate misrepresentation to gain promotion. This act likewise constituted falsification of an official document. Following Rule XIV of the Omnibus Rules Implementing Book V of the Administrative Code, both dishonesty and falsification of an official document are grave offenses punishable by dismissal. The penalty carries forfeiture of retirement benefits (except accrued leave credits) and disqualification from re-employment in any government agency. The Court imposed this penalty to uphold the integrity of the public service and the judicial branch.