AM P 12 3093; (March, 2014) (Digest)
G.R. No. A.M. No. P-12-3093. March 26, 2014.
Anonymous Complaint Against Otelia Lyn G. Maceda, Court Interpreter, Municipal Trial Court, Palapag, Northern Samar.
FACTS
An anonymous letter-complaint, claiming to be from a University of Eastern Philippines (UEP) student, was filed against Otelia Lyn G. Maceda, a Court Interpreter at the Municipal Trial Court (MTC) of Palapag, Northern Samar. The complaint alleged that Maceda falsified her Daily Time Records (DTRs) to reflect that she worked until 5:00 p.m. when, in fact, she would leave the office before 3:00 p.m. to travel approximately 70 kilometers to attend her law classes at UEP in Catarman, Northern Samar. The Office of the Court Administrator (OCA) referred the complaint for investigation. The investigating judge reported that Maceda admitted to being a law student since 2004 with permission from her former presiding judge, and that travel to UEP would require her to leave Palapag by 4:00 p.m. to attend 5:30 p.m. classes. The judge recommended dismissal. The OCA, however, recommended the complaint be re-docketed and that Maceda be found guilty of Dishonesty. In her defense, Maceda made a general denial, claimed she properly reported attendance, and argued the complaint was a facade by a rival for a promotion. She also contested the admissibility of the evidence (her school records and DTRs) and requested more time to secure counsel.
ISSUE
Whether Otelia Lyn G. Maceda is administratively liable for Dishonesty for falsifying her Daily Time Records to reflect official working hours while actually leaving early to attend law school classes.
RULING
Yes, Maceda is guilty of Less Serious Dishonesty. The Court found that the anonymous complaint was substantiated by verifiable public records. Her defense of having permission from a former judge to study law did not justify falsifying her DTRs, as such permission could not authorize dishonesty in the recording of official time. The Court also held that administrative proceedings are not bound by strict technical rules of evidence, and the documents, being part of her employee records, were admissible. Considering she had no prior administrative charges in her eleven years of service, no specific damage to the court was proven, and she did not take advantage of her position in committing the act, the offense was classified as Less Serious Dishonesty. The penalty imposed was suspension for six (6) months and one (1) day, with a stern warning.