G.R. No. P-05-1985; July 26, 2007
Civil Service Commission, Complainant, vs. Santos Enrie P. Perocho, Jr., Respondent.

FACTS

The Civil Service Commission (CSC) found respondent Santos Enrie P. Perocho, Jr., a Process Server at the Regional Trial Court (RTC) of Mandaluyong City, guilty of dishonesty. The CSC established that for his 1996 appointment as Clerk III, Perocho submitted a Personal Data Sheet (PDS) falsely stating he passed the April 17, 1994 Career Service Professional Examination with a rating of 85%. Verification with the CSC’s Examination and Placement Services Division confirmed his name was not in the Register of Eligibles for that exam. After a formal charge was issued, Perocho did not file an Answer and was deemed to have waived his right. Following an investigation where the prosecution presented confirming testimonial and documentary evidence, the CSC dismissed him from service with accessory penalties.
Before the Supreme Court, Perocho denied the allegations. He claimed he never received the formal charge or the CSC Decision, having moved residences. He asserted he only signed a mostly blank PDS given to him by a sheriff, did not make the false entry regarding eligibility, and informed the sheriff he was not eligible when he learned it was required. He denied receiving or assuming the Clerk III appointment and argued his current position as process server does not require such eligibility.

ISSUE

Whether respondent Santos Enrie P. Perocho, Jr. is guilty of dishonesty warranting dismissal from the service.

RULING

Yes, the Supreme Court found Perocho guilty of dishonesty and imposed the penalty of dismissal. The Court upheld the factual findings of the CSC, which are accorded respect and finality when supported by substantial evidence. Perocho’s defense of denial and non-receipt of notices was unavailing. His claim of signing a blank PDS was deemed inherently unbelievable, as a party is presumed to take ordinary care of his concerns and would not sign an important document without reading it. His subsequent act of accomplishing another PDS in 1997 demonstrated his familiarity with the form, further undermining his claim.
The Court emphasized that dishonesty is a grave offense punishable by dismissal for the first offense under the Uniform Rules on Administrative Cases. By falsifying his civil service eligibility to secure a permanent appointment, Perocho committed a deliberate act of dishonesty that violates the stringent standards of integrity demanded from all judiciary personnel. Such malevolent acts have no place in the judicial service, which requires the highest degree of probity from all its employees. Consequently, the Court affirmed his dismissal with forfeiture of retirement benefits and perpetual disqualification from re-employment in government.