A.M. No. 04-10-619-RTC; February 10, 2005
Disapproved Appointment of Noraina D. Limgas as Stenographer III, Regional Trial Court, Branch 8, Marawi City

FACTS

The Civil Service Commission (CSC) disapproved the permanent appointment of Noraina D. Limgas as Stenographer III of the RTC, Branch 8, Marawi City, after verification revealed her supporting Certificate of Rating was fake. The CSC confirmed that no Career Service Professional Examination was conducted in Cagayan de Oro City on March 28, 2003, as her certificate stated. Records showed a Subprofessional Computer Assisted Test was given on that date, where a certain Noraina D. Limgas obtained a failing mark of 25.63%. Consequently, her appointment was disapproved and her services were terminated.
In her defense, Limgas claimed she had no personal knowledge the certificate was fake, asserting it was the document she received after taking an exam on that date. She denied receiving a failing rating and portrayed herself as a victim of fixers within the CSC. The Office of the Court Administrator (OCA) found her explanation unsatisfactory and recommended she be found guilty of Dishonesty and Falsification of an Official Document.

ISSUE

Whether respondent Noraina D. Limgas is administratively liable for Dishonesty and Falsification of an Official Document.

RULING

Yes, the Supreme Court found Limgas guilty as charged. The legal logic rests on the inherent improbability of her defense and the duty of a public servant to ensure the integrity of documents submitted for appointment. The Court noted she admitted taking a Subprofessional examination, yet her Personal Data Sheet falsely declared she passed a Professional examination with a rating of 84.01%. This glaring discrepancy—between the level of exam taken and the eligibility claimed—negated her plea of good faith and lack of knowledge.
Good faith requires honesty of intention and freedom from knowledge of circumstances that should prompt inquiry. Upon receiving a certificate indicating a Professional Eligibility from an exam she knew was for the Subprofessional level, she had a clear duty to verify its authenticity with the CSC. Her failure to do so and her subsequent act of submitting the fabricated document to secure a permanent appointment constituted willful dishonesty and falsification. These are grave offenses under civil service rules, warranting dismissal even for a first offense. Accordingly, despite her prior termination, the Court imposed the penalty of dismissal with forfeiture of retirement benefits and disqualification from reemployment in government service.