A.M. No. P-10-2809; August 10, 2012
Manolito C. Villordon vs. Marilyn C. Avila, Court Interpreter I, MTCC, Branch 3, Cebu City

FACTS

Complainant Manolito C. Villordon, a BJMP employee, filed a complaint alleging that respondent Marilyn C. Avila, a Court Interpreter, committed dishonesty and falsification by making false entries in her Personal Data Sheet (PDS). Specifically, complainant alleged that respondent failed to declare her three illegitimate children and submitted a falsified income tax return. The complaint stemmed from a soured personal relationship between the parties. After their separation, respondent filed administrative and criminal cases against complainant. In turn, complainant filed this administrative case. During the investigation by the Executive Judge, respondent admitted omitting her children’s names from her PDS, claiming they were not her dependents and were in her parents’ custody. She also denied falsifying her civil status, asserting she was single. Complainant later filed a manifestation withdrawing his complaint, stating he filed it out of anger and was not a proper party.

ISSUE

Whether respondent Marilyn C. Avila is administratively liable for Dishonesty and Falsification of Official Document for her omissions in her Personal Data Sheet.

RULING

Yes, respondent is guilty as charged. The Supreme Court emphasized that the PDS is a vital document required by civil service rules, and its truthful accomplishment is a fundamental duty of every public servant. The Court rejected respondent’s justifications for omitting her children’s names. The requirement to list all children is mandatory, irrespective of their custody or dependency status, as the PDS serves as a means for the government to assess an employee’s background and integrity. The act of making an untruthful statement in an official document like the PDS constitutes dishonesty. Furthermore, such an act amounts to falsification as it impairs the document’s integrity and violates public faith, even absent an intent to injure a third party. The Court stressed that judicial employees must adhere to the highest standards of honesty and integrity. The subsequent desistance of the complainant does not divest the Court of its disciplinary authority, as administrative proceedings are aimed at preserving public interest in a clean judiciary, not merely settling private grievances. Given the gravity of dishonesty and falsification, which are considered grave offenses, the penalty of dismissal is mandatory under prevailing civil service rules. Accordingly, respondent was dismissed from service with forfeiture of benefits and disqualification from reemployment in government.