GR 238077; (March, 2021) (Digest)
G.R. No. 238077, March 17, 2021
Teddy L. Panarigan, Petitioner, vs. Civil Service Commission – Regional Office (CSCRO) No. III, Respondent.
FACTS
Petitioner Teddy L. Panarigan was employed at the National Food Authority (NFA) in Bulacan. In support of his application for a permanent Clerk II position, he submitted a Personal Data Sheet (PDS) on September 17, 2002, stating he obtained a rating of 82.16% in the Career Service Professional Examination (CSPE) taken on July 21, 2002, in Malolos, Bulacan. He was subsequently appointed. An anonymous letter later alleged his civil service eligibility was fake and that he paid another person to take the exam. Upon investigation requested by the NFA, the CSCRO found that the photograph and signature on the Picture Seat Plan (PSP) from the July 21, 2002 CSPE were different from those on Panarigan’s PDS. The CSCRO formally charged him with Dishonesty, Falsification of Official Document, and Conduct Prejudicial to the Best Interest of the Service. Panarigan denied the charges, claiming he personally took and passed the exam and was a victim of document tampering. The CSCRO found him guilty of Serious Dishonesty and Falsification of Official Document and imposed dismissal with accessory penalties. The Civil Service Commission (CSC) modified the finding to two counts of Serious Dishonesty but affirmed the penalty. The Court of Appeals affirmed with modification, finding him guilty of Serious Dishonesty, Grave Misconduct, and Falsification of Official Document.
ISSUE
Whether or not the Court of Appeals erred in finding Panarigan guilty of Serious Dishonesty, Grave Misconduct, and Falsification of Official Document.
RULING
The Petition lacks merit. The Supreme Court affirmed the findings of the Court of Appeals. The Court ruled that administrative agencies like the CSC are not bound by technical rules of evidence, and their factual findings, if supported by substantial evidence, are controlling. The photocopies of the PSP and examination application receipt, though not authenticated originals, were validly considered. CSC officials enjoy the presumption of regularity in administering examinations, and strict procedures make a mix-up highly unlikely. Panarigan’s defense of being framed was bare and unsubstantiated. His acts of employing another person to take the exam for him and falsely indicating in his PDS that he passed it constituted Serious Dishonesty, Grave Misconduct, and Falsification of Official Document. The penalty of dismissal from service with its accessory penalties, including forfeiture of retirement benefits (except accrued leave credits), cancellation of eligibility, disqualification from future civil service examinations, and perpetual disqualification from re-entering government service, was upheld.