G.R. No. A.M. No. 16-03-29-MTCC and A.M. No. 17-01-16-MTCC. September 29, 2020
IN RE: ALLEGED CIVIL SERVICE EXAMINATIONS IRREGULARITY OF MR. VILLAMOR D. BAUTISTA, CASHIER I, AND MS. ERLINDA T. BULONG, CLERK IV, OFFICE OF THE CLERK OF COURT, BOTH OF THE MUNICIPAL TRIAL COURT IN CITIES, SANTIAGO CITY, ISABELA; and IN RE: ANONYMOUS COMPLAINT AGAINST DOCKET CLERK ERLINDA BULONG

FACTS

The Civil Service Commission (CSC) referred an investigation to the Office of the Court Administrator (OCA) concerning alleged serious dishonesty by respondents Villamor D. Bautista and Erlinda T. Bulong, employees of the MTCC, Santiago City, Isabela. The charges stemmed from irregularities in their civil service examinations. For Bautista, the CSC found discrepancies between his photo in his Personal Data Sheet (PDS) and the photo in the picture seating plan for the 1997 exam. For Bulong, similar discrepancies were found for her 1998 exam. An anonymous complaint later echoed the allegations against Bulong.
During the investigation, Bautista denied the charge but failed to substantiate his claim of personally taking the exam. The investigating judge noted the person in the seating plan was a former co-worker. Bulong admitted she did not take the exam but claimed a “cultural minority eligibility.” However, she conceded that the exam result was reflected in her PDS, making it appear she took and passed it. The OCA adopted the investigating judge’s findings, noting both respondents enjoyed permanent positions without the requisite genuine eligibility.

ISSUE

Whether respondents Bautista and Bulong are guilty of Grave Misconduct, Dishonesty, and Falsification of Public Documents.

RULING

Yes, the Court found both respondents guilty as charged. Republic Act No. 9416 declares any form of cheating in civil service exams illegal, specifically defining cheating to include impersonation and possession/use of fake eligibility. The evidence conclusively established their guilt. For Bautista, a comparison of the picture seating plan and his PDS revealed different photographs and signatures. His defense of bare denial, unsupported by corroborating evidence, holds no evidentiary value. The Court noted the impersonator was his known former co-worker, a fact he did not credibly dispute.
For Bulong, her admission that she did not take the exam but still reflected the results in her PDS constitutes a clear admission of dishonesty and falsification. Her claim of lack of knowledge and her theory of a plot were properly brushed aside as unsubstantiated. The act of falsely claiming an eligibility to secure and retain a permanent government position undermines the integrity of the civil service. The Court emphasized that the offenses of dishonesty and falsification are grave in nature, warranting the supreme penalty of dismissal from service to preserve public trust in the judiciary. Accordingly, the Court dismissed Bautista and Bulong from service with forfeiture of all retirement benefits (except accrued leave credits) and perpetual disqualification from reemployment in any government agency.