A.M. No. P-97-1254 September 18, 1997
Anonymous vs. Adela A. Geverola, Clerk of Court IV, MTCC, Davao City

FACTS

An anonymous complaint charged respondent Adela A. Geverola, Clerk of Court IV of the MTCC in Davao City, with various offenses including falsification of daily time records, collecting salary while abroad, immorality, and accepting grease money. The Office of the Court Administrator (OCA) focused its investigation on the allegation concerning unauthorized foreign travel. Verification with the Bureau of Immigration and Deportation (BID) revealed that Geverola departed for Tokyo, Japan on June 5, 1993, and arrived from Seoul, South Korea on July 17, 1993.
Correlating these travel records with her official leave applications, the OCA found that Geverola had filed an application for sick leave covering July 1 to 9, 1993, supported by a Medical Certificate dated July 1, 1993, issued by a Davao City health officer. The certification stated she was suffering from “Pityriasis Rosea & Massive Allergy.” The incontrovertible immigration records proved she was outside the Philippines on all the dates covered by her sick leave application. She also received her salary and allowances for those dates.

ISSUE

Whether respondent Adela A. Geverola is administratively liable for dishonesty and falsification in connection with her fraudulent sick leave application.

RULING

Yes, respondent is administratively liable. The Court found the evidence of dishonesty and falsification to be clear and convincing. The legal logic rests on the direct contradiction between her official claim and the objective evidence. By filing a sick leave application for specific dates and submitting a medical certificate asserting she was in Davao City for treatment, she made a false representation of fact. The BID records irrefutably established her physical absence from the country during that entire period. This act constitutes falsification of an official document and dishonesty.
The Court emphasized the high standard of integrity required of all judiciary personnel, as public office is a public trust. As a Clerk of Court, a position of confidence demanding competence and honesty, her actions betrayed that trust and undermined public confidence in the administration of justice. While the Ombudsman had dismissed related criminal complaints for lack of witnesses, the administrative case proceeded based on the documentary evidence, which sufficed to establish liability under the lower standard of proof in administrative proceedings. Considering her 39 years of government service, the Court imposed a two-month suspension without pay and ordered her to refund the salary and allowances overpaid for the fraudulent leave period.