A.M. No. P-99-1336, February 6, 2001
Clerk of Court Eleonor T.F. Marbas-Vizcarra vs. Ma. Dina A. Bernardo

FACTS

This administrative case originated from an investigation conducted by complainant Clerk of Court Eleonor T.F. Marbas-Vizcarra of the Regional Trial Court (RTC), Branch 30, Cabanatuan City. The investigation was prompted by letters from the Supreme Court’s Chief Administrative Officer, Atty. Adelaida Cabe-Baumann, reporting tampered Daily Time Records (DTRs) for November and December 1994 of several court employees. Atty. Vizcarra’s inquiry revealed that the tampering was committed by respondent Ma. Dina A. Bernardo, a Clerk III, and her co-employee, Gregoria R. Florendo, a Court Interpreter.
The investigation established that the DTRs, which had been entrusted to Florendo for submission to the Supreme Court, were falsified in Florendo’s house the night before their transmittal. Bernardo and Florendo tampered not only their own DTRs but also those of other employees, including Juanito Florendo, Linafe Quijano, and Josefina Cunanan, without the latter’s knowledge or consent. Witness statements, including one from Juanito Florendo who was present but intimidated, corroborated the acts. Bernardo initially admitted participation orally but was evasive in her written statement.

ISSUE

Whether respondent Ma. Dina A. Bernardo should be held administratively liable for her actions in tampering with official Daily Time Records.

RULING

Yes, respondent is administratively liable and is dismissed from service. The Court found the acts of tampering with or falsifying DTRs to constitute the grave offense of falsification of official documents under Section 22(f) of the Omnibus Civil Service Rules and Regulations. This offense is punishable by dismissal even for a first offense. The legal logic is straightforward: DTRs are official documents vital to personnel management and payroll integrity within the judiciary. Deliberately altering them to reflect false attendance data is a direct falsification that undermines administrative integrity and public accountability.
The Court emphasized that all judiciary personnel must uphold the highest standards of conduct, as their behavior directly impacts public trust in the justice system. By engaging in falsification, Bernardo demonstrated a blatant disregard for these standards. Her actions, committed in conspiracy with another employee, were not mere lapses but deliberate dishonesty that eroded the ethical foundation required of a public servant in the judiciary. The penalty of dismissal, with forfeiture of benefits and disqualification from reemployment, is imposed to preserve the integrity of the judicial service and to deter similar misconduct. The Court cannot tolerate any act that diminishes the people’s faith in the administration of justice.