AM 04 10 637 RTC; (August, 2005) (Digest)
A.M. No. 04-10-637-RTC. August 18, 2005. Disapproved Appointment of Maricel A. Cubijano, Court Stenographer III, RTC-Branch 28, Lianga, Surigao Del Sur.
FACTS
Maricel A. Cubijano was issued a temporary appointment as Court Stenographer III in July 2002, which was renewed in May 2003. In March 2004, she received a permanent appointment. The Civil Service Commission (CSC) disapproved this permanent appointment upon discovering that her name did not appear in the official roster of eligibles and that the Certificate of Rating for the Career Service Professional Examination she submitted was fake. When required to comment, Cubijano argued the case was moot as her employment had been terminated in June 2004 due to the expiration of her term. She claimed good faith, asserting she believed the certificate was authentic, and contended she caused no damage to the government as she allegedly received no salary or compensation.
ISSUE
Whether Cubijano should be held administratively liable for submitting a fake Certificate of Eligibility for her appointment.
RULING
Yes, Cubijano is guilty of Dishonesty. The Court found that the use of a false certificate of eligibility constitutes a grave act of dishonesty under the Uniform Rules on Administrative Cases. Her defense of good faith is untenable, as she later admitted in her letter that the certificate “turned out to be fake.” The claim that she caused no injury is also false; records show she was paid her salary from her initial temporary appointment in 2002 until her separation. The government was prejudiced as the court was deprived of hiring a genuinely qualified applicant.
Although her dismissal is no longer feasible due to the prior termination of her employment, the Court imposed consequential penalties. Following established precedent, the Court ordered the forfeiture of all her benefits, except accrued leave credits, and perpetually disqualified her from re-employment in any government branch, agency, or instrumentality. The judiciary demands the highest standards of integrity, and dishonesty, a malevolent act, warrants the severest sanctions to preserve public trust in the justice system.