A.M. No. P-985 July 31, 1978
Eugenio Dela Cruz, complainant, vs. Roberto Mudlong, respondent.

FACTS

Respondent Roberto Mudlong was appointed as a Process Server in the Circuit Criminal Court in Cabanatuan City. An administrative complaint was filed against him for “oppression, misconduct, and being notoriously undesirable.” The Supreme Court referred the matter for investigation. The core of the complaint was Mudlong’s failure to disclose material information in his Civil Service Form No. 1 (1968) and Personal Data Sheet (CS Form No. 212, 1968 and 1975) submitted for his appointment and promotion. The investigation revealed that in his 1968 forms, he answered “no” to questions asking if he had ever been accused, indicted, or tried for any violation of law or been the subject of an administrative case.
The truth was that in 1962, he had been charged with Maltreatment and Light Threats before a Justice of the Peace Court and found guilty of Misconduct in an administrative case before a Municipal Council, resulting in a 15-day suspension. In his 1975 data sheet submitted to the Supreme Court, he partially disclosed some cases but omitted others. He presented defenses, including affidavits of desistance from the complainant and dismissals of the criminal cases, and argued that the withdrawn complaint should end the matter.

ISSUE

Whether respondent Roberto Mudlong is administratively liable for dishonesty and falsification in his personal data sheets, warranting dismissal from service.

RULING

Yes, the respondent is guilty as charged and is dismissed from service. The legal logic is clear: employees in the judiciary must uphold the highest standards of honesty and integrity. The requirement to completely and truthfully disclose one’s personal history in official forms is fundamental, as these documents are crucial for assessing an applicant’s fitness and moral character for public office. By willfully concealing his prior criminal accusations and an administrative conviction, Mudlong committed acts of dishonesty and falsification.
The Court rejected his defenses. The dismissal of the criminal cases based on the complainant’s desistance does not equate to a finding of innocence nor absolve him of the administrative offense of concealment. The act of suppression itself is the violation, independent of the final outcome of the concealed cases. Furthermore, the withdrawal of the administrative complaint by the complainant is immaterial, as the Court can initiate disciplinary action sua sponte based on the evidentiary record of the falsification. Such a breach of trust is grave and undermines the integrity of the judicial service. Consequently, dismissal with forfeiture of benefits and disqualification from re-employment in any government agency is the appropriate penalty.