G.R. No. A.M. No. P-06-2111. February 8, 2012.
ANNABELLE F. GARCIA, CLERK OF COURT, MUNICIPAL TRIAL COURT IN CITIES, BRANCH 2, OLONGAPO CITY, Complainant, vs. HERMINIO C. REYES AND ZOSIMA S. DE VERA, INTERPRETER AND STENOGRAPHER, RESPECTIVELY, MUNICIPAL TRIAL COURT IN CITIES, BRANCH 2, OLONGAPO CITY, Respondents.

FACTS

Annabelle F. Garcia, Clerk of Court of MTCC Branch 2 in Olongapo City, issued a memorandum requiring court interpreter Herminio C. Reyes and stenographer Zosima S. De Vera to explain why no disciplinary action should be taken against them for violating Civil Service rules. The complaint alleged that on November 26, 2004, both respondents left the office before the official end of the workday at 5:00 p.m. and requested utility aide Amelia Gonzales Pronto to punch their respective time cards to falsely reflect their attendance.
In their explanations, Reyes admitted leaving at 11:40 a.m. for a medical consultation but claimed he returned after thirty minutes and personally punched out at 5:00 p.m., denying Pronto did it for him. De Vera admitted leaving at around 4:30 p.m. to escort relatives, requesting Pronto to punch her card only if she failed to return on time, which occurred. She also contended Garcia should be similarly charged for attesting to the truth of her Daily Time Record.

ISSUE

Whether respondents Reyes and De Vera are administratively liable for their actions concerning their attendance records on November 26, 2004.

RULING

Yes, the Supreme Court found both respondents administratively liable for Dishonesty. The legal logic centers on the fundamental principle that court personnel must be exemplars of integrity and strict discipline, as public office is a public trust. By leaving work early and arranging for another person to punch their time cards, respondents committed acts of dishonesty intended to misrepresent their actual hours of service, in direct violation of Supreme Court Circulars (e.g., Circular No. 2-99) mandating strict observance of prescribed working hours.
The Court rejected Reyes’s denial that Pronto punched his card, finding his admission of requesting her to do so sufficient to establish liability. For De Vera, her own admission confirmed the infraction. While dishonesty is a grave offense potentially punishable by dismissal, the Court considered mitigating circumstances. For Reyes, his length of service was a mitigating factor, though his liability was aggravated by a prior similar offense. For De Vera, her admission of the act served as mitigation. Consequently, the Court imposed fines instead of dismissal: ₱10,000.00 on Reyes and ₱7,000.00 on De Vera, with a stern warning against repetition. The Court also directed the Office of the Court Administrator to file the necessary administrative complaint against Amelia G. Pronto.