A.M. No. 14-10-314-RTC November 28, 2017
Anonymous Complaint dated May 3, 2013, Re: Fake Certificates of Civil Service Eligibility of MARIVIC B. RAGEL, EVELYN C. RAGEL, EMELYN B. CAMPOS, and JOVILYN B. DAWANG

FACTS

An anonymous complaint alleged that the civil service eligibilities of four court personnel were spurious. The Civil Service Commission (CSC) verified that while the names were in its records, a comparison of the photographs in the examinees’ Picture-Seat Plans with those in the respondents’ Personal Data Sheets (PDS) revealed discrepancies in facial features for Evelyn Ragel, Emelyn Campos, and Jovilyn Dawang. The Court dismissed the case against Marivic Ragel, while Dawang was separately dismissed in another administrative case. Evelyn Ragel and Emelyn Campos were required to comment.
In their Comments, Ragel and Campos denied the allegations, asserting they personally took their respective civil service examinations and signed the records. The OCA, upon further correspondence with the CSC, obtained authenticated enlarged reproductions of the Picture-Seat Plans for the examinations in question.

ISSUE

Whether respondents Evelyn C. Ragel and Emelyn B. Campos are administratively liable for dishonesty based on the alleged use of fake civil service eligibility certificates.

RULING

Yes, the respondents are guilty of dishonesty. The Court upheld the findings and recommendation of the OCA. The evidence, particularly the side-by-side comparison of the photographs from the CSC’s Picture-Seat Plans and the respondents’ own PDS, clearly showed distinct differences in facial features. The Court noted that the differences were so apparent that an ordinary person could easily discern the individuals were not the same. Furthermore, a variance in the signatures appearing on the examination records and the PDS provided additional evidence of impersonation.
The Court found the respondents’ bare denials unavailing. Denial is an inherently weak defense that must be supported by strong evidence of non-culpability; otherwise, it is a self-serving assertion with no evidentiary value. The positive evidence from the CSC records established that the persons who took the examinations were not Ragel and Campos. Citing Civil Service Commission v. Dasco, the Court reasoned that such impersonation could not have occurred without the respondents’ active participation and knowledge, and they subsequently benefited from the passing results.
Dishonesty is a grave offense punishable by dismissal. As court personnel, respondents are held to the highest standards of integrity. Their act of dishonesty violated these stringent standards and warranted their removal from the judiciary to preserve its integrity. Consequently, the Court DISMISSED Evelyn C. Ragel and Emelyn B. Campos from service with forfeiture of all retirement benefits (except accrued leave credits) and with prejudice to re-employment in any government branch or instrumentality.