GR 167916; (August, 2008) (Digest)
G.R. No. 167916; August 26, 2008
SARAH P. AMPONG, petitioner, vs. CIVIL SERVICE COMMISSION, CSC-Regional Office No. 11, respondents.
FACTS
Petitioner Sarah P. Ampong, while a public school teacher under the Department of Education, Culture and Sports (DECS), took and passed the November 1991 Professional Board Examination for Teachers (PBET) under the name of Evelyn Junio-Decir. In 1994, when a woman claiming to be Decir attempted to claim the certificate of eligibility, Civil Service Commission (CSC) Regional Office No. XI personnel discovered the impersonation. An investigation confirmed Ampong was the actual examinee. The CSC formally charged both Ampong and Decir with Dishonesty, Grave Misconduct, and Conduct Prejudicial to the Best Interest of the Service.
Ampong later transferred to the judiciary, appointed as Court Interpreter III at the Regional Trial Court of Alabel, Sarangani Province, on August 3, 1993. During the CSC proceedings, Ampong voluntarily admitted to the wrongdoing in sworn statements, waiving her right to counsel and to a formal hearing. The CSC found her guilty and imposed the penalty of dismissal. Ampong challenged the CSC’s jurisdiction, arguing that as a court employee at the time of the charge, the Supreme Court, not the CSC, had administrative supervision over her.
ISSUE
Whether the Civil Service Commission properly exercised jurisdiction over the administrative case against petitioner, a court employee, for acts committed prior to her appointment to the judiciary.
RULING
Yes, the CSC properly exercised jurisdiction. The Supreme Court ruled that the CSC retains jurisdiction over administrative cases involving acts committed by a government employee prior to a transfer to another agency, including the judiciary. The offense of dishonesty was committed in 1991 when Ampong was a public school teacher under the DECS, an agency within the CSC’s administrative disciplinary authority. Jurisdiction is determined by the employee’s official affiliation at the time of the alleged misconduct, not at the time of the filing of the charge.
The Court clarified that while the Supreme Court has administrative supervision over all courts and their personnel under the Constitution, this power is prospective and pertains to conduct committed during their incumbency in the judiciary. The principle of concurrent jurisdiction between the CSC and the Supreme Court over court employees does not apply where the actionable wrong predates judicial employment. To hold otherwise would allow an employee to evade liability by simply transferring to a different branch of government. Ampong’s subsequent appointment to the judiciary did not divest the CSC of its validly acquired jurisdiction over the case stemming from her prior acts as a teacher. Her admissions, made knowingly and with a waiver of rights, substantiated the charges.