G.R. No.: A.M. No. P-14-3218, July 8, 2014
Case Parties: Selection and Promotion Board, Office of the Court Administrator, Complainant, vs. Ronaldo D. Taca, Cashier I, Metropolitan Trial Court, Office of the Clerk of Court, Manila, Respondent.

FACTS

Respondent Ronaldo D. Taca, a Cashier I at the Office of the Clerk of Court of the Metropolitan Trial Court of Manila since April 8, 1997, applied for promotion to Cashier II and III in 2012. The Selection and Promotion Board (OCA-SPB) noted discrepancies in his Personal Data Sheet (PDS) regarding his college educational attainment and the date of his civil service examination. An investigation revealed multiple inconsistent entries across PDS forms submitted from 1991 to 2010. Specifically, in forms dated May 6, 1991, January 6, 1997, and October 15, 2001, he indicated “B.S. Psychology” as his degree earned from Far Eastern University, despite having only completed 101 units at that university and not actually graduating until 2010 from New Era University with a BSBA in Banking and Finance. The position of Cashier I, to which he was appointed in 1997, required a bachelor’s degree and Career Service (Professional) eligibility. Respondent claimed the discrepancies were due to “hastiness and negligence” and a misunderstanding that “degrees” and “units” earned meant the same.

ISSUE

Whether respondent Ronaldo D. Taca committed dishonesty and falsification of public documents by making false entries in his Personal Data Sheets.

RULING

Yes, the Supreme Court found respondent guilty of dishonesty and falsification of public documents. The Court adopted the findings and recommendations of the Office of the Court Administrator (OCA). The false statements in his PDS, particularly misrepresenting that he held a Bachelor’s degree in Psychology at the time of his appointment in 1997 when he did not, were made to secure a position for which he was not qualified. This act of deception prejudiced other qualified applicants. His subsequent attainment of a degree in 2010 did not mitigate his liability. The Court emphasized that the PDS is an official document, and making false statements therein constitutes falsification. Citing jurisprudence, the Court stressed that court personnel must uphold the highest standards of honesty and integrity. Dishonesty, being a grave offense punishable by dismissal even for the first offense under the Civil Service Rules, warranted the severest penalty. Respondent Ronaldo D. Taca was DISMISSED from service with FORFEITURE of all retirement benefits (except accrued leave credits) and with prejudice to re-employment in any government agency, including government-owned or controlled corporations.