A.M. No. P-15-3289, February 17, 2015
Civil Service Commission, as represented by Director IV Maria Leticia G. Reyna, Complainant, vs. Jovilyn B. Dawang, Court Stenographer I, Municipal Trial Court, Talugtog, Nueva Ecija, Respondent.

FACTS

Respondent Jovilyn B. Dawang, a Court Stenographer I, was charged with serious dishonesty by the Civil Service Commission (CSC). The charge stemmed from the Career Service Professional Examination held on August 18, 1996. The CSC alleged that Dawang, then Jovilyn S. Borillo, conspired with an impersonator who took the examination on her behalf. The impersonator’s photograph was placed on the picture-seat plan under Dawang’s name. The impersonator passed, and a Certificate for Career Service Professional Eligibility was issued to Dawang. Dawang subsequently filed a modified Personal Data Sheet on October 11, 1996, indicating she possessed the “Career Service Professional” eligibility with a rating of 84.86%. In 2007, upon Dawang’s request for authentication of her certificate, the CSC’s Integrated Records Management Office noted marked differences in the facial features and signatures between the picture-seat plan and Dawang’s identification documents, indicating two different individuals. After investigation and a failure by Dawang to comply with a Show Cause Order, the CSC found a prima facie case and formally charged her. In her defense, Dawang claimed she was a victim, narrating that a man posing as a CSC lawyer-employee handled her application and later informed her she passed without her having taken the exam. She verified this with a CSC clerk and then used the eligibility to gain permanent status.

ISSUE

Whether respondent Jovilyn B. Dawang is guilty of serious dishonesty warranting dismissal from service.

RULING

Yes, the Supreme Court found respondent guilty of serious dishonesty. The Court agreed with the findings of the Office of the Court Administrator and the CSC, noting the apparent differences between the photograph on the examination picture-seat plan and Dawang’s photographs, concluding they were different individuals. The Court held that allowing another to take an examination on one’s behalf is an act of dishonesty. Even assuming Dawang’s narrative was true, her subsequent actions constituted serious dishonesty: she accepted the eligibility certificate despite knowing she did not take the exam, failed to inquire about the missing exam notice, and then willfully declared the ill-gotten eligibility and exam details under oath in her Personal Data Sheet to secure permanent employment. The Court cited Civil Service Commission v. Dasco, emphasizing that judiciary employees must be examples of integrity and that dishonesty warrants dismissal. Under the Revised Rules on Administrative Cases, serious dishonesty is a grave offense punishable by dismissal.
DISPOSITIVE:
Respondent Jovilyn B. Dawang is DISMISSED from service with FORFEITURE of all retirement benefits except accrued leave credits and with prejudice to re-employment in any government branch, instrumentality, or government-owned or controlled corporation.