G.R. No. 203536 , February 4, 2015
CIVIL SERVICE COMMISSION, Petitioner, vs. MARIA RIZA G. VERGEL DE DIOS, Respondent.

FACTS

The Civil Service Commission (CSC) conducted an investigation based on an anonymous complaint alleging that several employees of San Rafael Water District used a fixer to pass the CSC Career Service Professional Examination on November 17, 2000. During the investigation, CSC Director Aurora C. De Leon received information implicating respondent Maria Riza G. Vergel de Dios. Verification with CSC records revealed discrepancies between the signatures and pictures on respondent’s personal data sheets and those on the picture seat plan used for the examination. Consequently, the CSC formally charged respondent with dishonesty, grave misconduct, falsification of official documents, and conduct prejudicial to the best interest of the service. In her defense, respondent testified that she personally took the examination, supported by a witness, Loline Padilla, who accompanied her but admitted not seeing her actually take the exam. The CSC Regional Office found respondent guilty and dismissed her from the service, a decision affirmed by the CSC Central Office. The Court of Appeals initially upheld the CSC but, on reconsideration, reversed the dismissal, speculating that the discrepancies could be due to a mix-up, especially since the room examiners were not presented to prove strict adherence to examination procedures.

ISSUE

Whether the Court of Appeals erred in reversing the Civil Service Commission’s ruling that found respondent guilty based on discrepancies in her pictures and signatures between the picture seat plan and personal data sheets, attributing these discrepancies to a possible mix-up.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the CSC resolutions. The Court held that the CA’s finding of a possible mix-up was pure speculation unsupported by evidence. The Court examined the records and agreed with the CSC’s detailed finding that the facial features and signatures on the picture seat plan and personal data sheets were obviously different, indicating they were made by two different persons. The Court emphasized that the picture seat plan is a public document, admissible as prima facie evidence without need for proof of authenticity, and that CSC examiners enjoy the presumption of regularity in the performance of their official duties. The presentation of room examiners was not required to establish the observance of procedures or the documents’ authenticity. The discrepancies constituted misrepresentation in the personal data sheet and fraudulent procurement of civil service eligibility, warranting dismissal from service.