G.R. No. 206379 November 19, 2014
CECILIA PAGADUAN, Petitioner, vs. CIVIL SERVICE COMMISSION and REMA MARTIN SALVADOR, Respondents.

FACTS

On May 14, 1992, petitioner Cecilia Pagaduan filed an administrative complaint with the Civil Service Commission-Regional Office No. II (CSC-RO II) against respondent Rema Martin Salvador, a newly appointed Municipal Budget Officer, charging her with falsification and misrepresentation. Pagaduan alleged that Salvador falsely indicated in her Personal Data Sheet (PDS) that she performed bookkeeping and accounting functions for Veteran’s Woodworks, Inc. (VWI) from August 1, 1990 to February 15, 1992, and did not possess the required budgeting experience. On May 22, 2000, the CSC-RO II found Salvador liable only for Simple Misconduct and imposed a one-month suspension. This decision became final and executory, and Salvador served the penalty.
Separately, on October 19, 1994, Pagaduan filed a criminal case for falsification of public documents against Salvador before the Municipal Trial Court in Cities (MTCC). On October 22, 2008, the MTCC found Salvador guilty of falsification. Salvador did not appeal and was placed on probation.
Subsequently, Pagaduan filed a second administrative complaint against Salvador, this time for the offense of conviction of a crime involving moral turpitude, based on the MTCC’s criminal conviction. On January 12, 2010, the CSC-RO II found Salvador guilty and imposed the penalty of dismissal. On appeal, the Civil Service Commission (CSC) reversed the CSC-RO II and exonerated Salvador, ruling that the falsification did not per se involve moral turpitude, citing that her liability in the first administrative case was only for Simple Misconduct. Pagaduan appealed to the Court of Appeals (CA), which initially reversed the CSC and affirmed the CSC-RO II’s dismissal order. However, upon Salvador’s motion for reconsideration, the CA issued an Amended Decision reinstating the CSC’s exoneration, agreeing that the falsification was a mere error of judgment and did not involve moral turpitude. Hence, this petition.

ISSUE

Whether respondent Rema Martin Salvador was convicted of a crime involving moral turpitude, warranting her dismissal from the service.

RULING

No. The Supreme Court denied the petition and affirmed the Amended Decision of the Court of Appeals. The Court held that not every crime of falsification of a public document involves moral turpitude. Moral turpitude implies an act of baseness, vileness, or depravity contrary to accepted moral standards. The determination depends on the circumstances of each case. Here, Salvador’s falsification in her PDS, by claiming employment with VWI, was done to meet the experience requirement for the position of Municipal Budget Officer. The Court found no evidence of a malicious intent to injure a third party or to attain a wrongful purpose. Her act was an error of judgment, not one involving moral turpitude. The Court also noted that in the first administrative case, she was found liable only for Simple Misconduct, and the criminal conviction did not automatically characterize the act as one involving moral turpitude. The procedural defenses of res judicata and forum shopping raised by Salvador were not addressed as the Court resolved the case on substantive grounds.