AM P 1551; (January, 1979) (Digest)
A.M. No. P-1551. January 15, 1979. JUANITO BENAOJAN, complainant, vs. MARIANO LACSON, respondent.
FACTS
Complainant Juanito Benaojan, an interpreter, charged respondent Mariano Lacson, a court clerk, with falsifying his personal data sheets. The documents, subscribed in 1974 and 1975, falsely stated that Lacson graduated with an Associate in Arts (Pre-law) from the University of the East in 1952 and finished law at the University of Manila in 1967. Certifications from the registrars of both universities, dated July 30, 1976, confirmed he was never enrolled. Lacson, in his answer, argued the sheets were never used for promotion and that falsification required intent to injure a third party, which was absent.
The case was referred for investigation. The report established that Lacson, then detailed in Iligan City, used the August 1975 information sheet to support a recommendation for promotion to Deputy Clerk of Court. The May 1975 sheet was filed to comply with a Supreme Court memorandum to update personnel records. The Investigating Judge found Lacson made untruthful statements about his educational attainment, constituting dishonesty.
ISSUE
Whether respondent Mariano Lacson is administratively liable for the misrepresentations in his personal data sheets.
RULING
Yes, respondent is guilty of gross dishonesty warranting dismissal. The Court rejected Lacson’s defenses. First, his claim that the data sheets were not used for promotion was contradicted by evidence showing the 1975 sheet accompanied a recommendation for a higher position. Second, his argument that there was no intent to injure a third party is irrelevant in an administrative proceeding, which focuses on fitness for public service, not the elements of a criminal offense. The act of submitting falsified official documents to superiors, whether for promotion or compliance with a lawful order, is intrinsically dishonest.
The Court found the Investigating Judge’s recommended penalty of a three-month salary fine too lenient. Lacson’s repeated misrepresentations over an extended period demonstrated a deliberate pattern to deceive. Such conduct constitutes a blatant betrayal of public trust, violating the constitutional mandate that public office is a public trust requiring the highest degree of integrity. To uphold this standard, dismissal is the appropriate sanction. Accordingly, the Court ordered Lacson’s dismissal from service with forfeiture of all retirement benefits and with prejudice to re-employment in any government agency.