G.R. No. 238774 , June 10, 2020
CIVIL SERVICE COMMISSION, PETITIONER, VS. HILARIO J. DAMPILAG, RESPONDENT.

FACTS

An anonymous complaint was filed alleging that Hilario J. Dampilag committed an examination irregularity. The Civil Service Commission-Cordillera Administrative Region (CSC-CAR) found glaring disparities between the facial features and signatures in the Picture Seat Plan (PSP) for the December 1, 1996 Career Service Professional Examination (CSPE) and Dampilag’s Personal Data Sheet (PDS) accomplished on March 3, 1999. The PDS indicated he passed the CSPE with a rating of 81.89. The CSC-CAR charged Dampilag with Serious Dishonesty, Falsification of Official Documents, and Grave Misconduct, alleging he allowed another person to take the exam in his behalf and misrepresented the result in his PDS. Dampilag admitted the person in the PSP photograph was not him but his former board mate, Bong Martin, claiming he inadvertently submitted the wrong photo from an improvised envelope containing both pictures. He argued any signature disparities were due to the lapse of time and lack of intent to mislead. The CSC-CAR found him guilty and imposed dismissal. The CSC affirmed but modified the finding to two counts of Serious Dishonesty: one for examination impersonation and another for fraud/falsification in his PDS. The Court of Appeals (CA) reversed and exonerated Dampilag, noting the PSP and PDS were not part of the CA records and relying instead on other submitted documents showing variations in his signature over time. The CSC, through the Office of the Solicitor General, filed this petition.

ISSUE

Whether the Court of Appeals erred in exonerating Dampilag of two counts of Serious Dishonesty.

RULING

Yes. The Supreme Court granted the petition, reversed the CA Decision, and reinstated the CSC Resolution finding Dampilag guilty of two counts of Serious Dishonesty and imposing the penalty of dismissal with its accessory penalties. The Court held that substantial evidence supported the CSC’s findings. A comparison of the PSP and PDS revealed glaring disparities in both the photograph and the signature, leading to the reasonable conclusion that another person took the examination for Dampilag. His defense of inadvertence was unconvincing, as exam proctors would not allow a person who did not match the submitted photograph to take the test. The Court further ruled that the CSC, as an expert body on civil service matters, could make its own comparison of the signatures without needing a handwriting expert, as the differences were apparent to the naked eye. By stating in his PDS that he passed the CSPE when he did not personally take it, Dampilag committed falsification and serious dishonesty. The offense constituted two counts: first, for examination impersonation, and second, for falsifying his PDS. The penalty of dismissal was appropriate.