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, then a public school teacher, took and passed the November 1991 Professional Board Examination for Teachers (PBET) using the name of her relative, Evelyn Junio-Decir. In 1993, Ampong transferred to the judiciary, appointed as Court Interpreter III of the Regional Trial Court. In 1994, the Civil Service Commission (CSC) Regional Office discovered the impersonation when a woman claiming to be Decir attempted to claim the certificate. The CSC formally charged both Ampong and Decir with Dishonesty, Grave Misconduct, and Conduct Prejudicial to the Best Interest of the Service. Ampong voluntarily admitted to the wrongdoing before the CSC in 1995, waiving her right to counsel and a formal hearing.
ISSUE
Whether the Civil Service Commission properly exercised jurisdiction over the administrative case against Ampong for acts committed while she was a public school teacher, prior to her appointment in the judiciary.
RULING
No. The Supreme Court ruled that the CSC lost jurisdiction over Ampong upon her appointment to the judiciary. The legal logic is anchored on the principle of jurisdiction by the nature of the position held at the time of the administrative proceeding. While the CSC has original jurisdiction over civil service offenses, its authority is limited to officials and employees within the executive branch. Upon Ampong’s appointment as a court interpreter, she became part of the judiciary and fell under the Supreme Court’s exclusive administrative supervision pursuant to Article VIII, Section 6 of the Constitution . The Court clarified that jurisdiction is determined by the office held by the person at the time of the filing of the complaint, not when the offense was committed. Therefore, the administrative case should have been filed with and investigated by the Supreme Court. The Court further noted that Ampong’s admissions before the CSC, made without the assistance of counsel, could not bind the Court in a subsequent proceeding, as the constitutional rights during custodial investigation apply by analogy to administrative cases where the penalty is removal. The CSC’s decision was annulled and the case was referred to the Office of the Court Administrator for appropriate action.