A.M. No. 2002-8-SC December 18, 2002
Zenaida de Guzman vs. Antonio delos Santos, Information Officer III, Publication and Circulation Division, Office of the Reporter (Supreme Court)

FACTS

Respondent Antonio delos Santos, an Information Officer III at the Supreme Court, applied for promotion to Information Officer IV. In his attached Personal Data Sheet (Civil Service Form 212), he stated under Item 18 that he graduated from Manuel L. Quezon University (MLQU) in 1992 with a Bachelor of Science in Electrical Engineering (BSEE) degree. He was among three applicants recommended, and his appointment was approved on February 27, 2002. Complainant Zenaida de Guzman alleged that respondent misrepresented his educational attainment, as verified by the Commission on Higher Education (CHED). The MLQU Registrar certified that, based on their records, respondent lacked 17 units to finish a Bachelor of Science in Mechanical Engineering (BSME) as of the second semester of 1981-82. In his comment, respondent claimed he transacted with a person named “Mario” from the MLQU Registrar’s Office who facilitated his enrollment, assured him of passing grades, and provided him with a diploma and transcript of records in 1992, leading him to believe in good faith that he was a graduate. He stated his academic documents were lost after a robbery in December 1992. The Office of Administrative Services found him liable for dishonesty, misconduct, and falsification of an official document.

ISSUE

Whether respondent Antonio delos Santos is administratively liable for dishonesty and falsification of an official document for falsely stating in his Personal Data Sheet that he was a BSEE graduate from MLQU.

RULING

Yes, respondent is administratively liable. The Supreme Court ruled that making a false statement in a Personal Data Sheet, a mandatory requirement for government employment, constitutes dishonesty and falsification of an official document, warranting dismissal from service upon the first offense. The Court found that respondent could not claim good faith, as the circumstances of his transaction with “Mario” were unusual and improbable, sufficient to provoke suspicion about the authenticity of his diploma. His false statement was intimately connected with his employment and promotion. Public office is a public trust, requiring the highest standards of ethical conduct, including honesty and faithful compliance with the law. Consequently, respondent Antonio delos Santos is DISMISSED from the service with prejudice to re-employment in any government agency and government-owned or controlled corporation, with forfeiture of retirement benefits, except accrued leave credits earned prior to December 10, 1991.