G.R. No. 248255 , August 27, 2020
Civil Service Commission, Petitioner, vs. Marilou T. Rodriguez, Respondent.

FACTS

Respondent Marilou T. Rodriguez took the Nursing Licensure Examination (NLE) in 1988. The results, published in a newspaper, did not include her name. Nevertheless, in 1989, she applied and was accepted as a staff nurse at the Davao Oriental Provincial Hospital by submitting a document showing a passing rate of 79.6% and a “PRC Identification Card.” From 1989 to 2000, in her Personal Data Sheets for appointment and promotion, she consistently declared she passed the 1988 NLE with a 79.6% rating and possessed a valid PRC ID. She resigned on July 31, 2002. In 2013, after working abroad and having passed the NLE in 2009, she was appointed as a nurse at the Office of City Health Officer, Mati, Davao Oriental. In 2014, the CSC Regional Office issued a Show Cause Order after verification with the PRC revealed that the PRC ID with license number 0158713 she had submitted belonged to another person, Ella S. Estopo. Respondent admitted the PRC ID was fake but claimed good faith, alleging she was deceived by a certain Evelyn Sapon who told her she was on a “deferred status” list and provided the card. The CSC Regional Office found her guilty of serious dishonesty, grave misconduct, conduct prejudicial to the best interest of the service, and falsification of official document, and ordered her dismissal with accessory penalties. The CSC Proper affirmed but modified, ruling falsification was subsumed in serious dishonesty. The Court of Appeals reversed, dismissing the charges and ordering her reinstatement, finding she acted in good faith and demonstrated remorse.

ISSUE

Did the Court of Appeals commit reversible error in clearing respondent of administrative liability for her submission and use of a spurious NLE rating and PRC Identification Card and for falsely declaring in her Personal Data Sheets that she was a registered nurse?

RULING

Yes. The Supreme Court reversed the Court of Appeals and reinstated the Decision of the Civil Service Commission. The Court held that respondent committed serious dishonesty, grave misconduct, and conduct prejudicial to the best interest of the service. Her claim of good faith was unsubstantiated. Her acts of misrepresentation were deliberate and continued over many years, enabling her to secure employment and promotions. Administrative offenses do not prescribe, and her subsequent resignation and re-employment did not moot the case. Her actions constituted a clear violation of the Philippine Nursing Law, which prohibits the practice of nursing without a valid certificate of registration. The penalty of dismissal from the service with all its accessory penalties was imposed.