G.R. No. 255286, November 13, 2023
CIVIL SERVICE COMMISSION, PETITIONER, VS. EPIFANY ALONZO, RESPONDENT.

FACTS

Respondent Epifany Alonzo, a member of the Philippine National Police (PNP), was issued a promotional appointment as Senior Police Officer 2 (SPO2). In support of this, he submitted a Personal Data Sheet (PDS) stating he was a graduate of AB Economics from Albayog Community College (ACC), along with a purported Transcript of Records (TOR). The Civil Service Commission Regional Office (CSCRO-8) verified his records with ACC. The school’s new Registrar certified that while Alonzo had enrolled, there was no record of his graduation, leading the CSC to recall and disapprove his appointment.
The CSCRO-8 subsequently filed an administrative case against Alonzo for Serious Dishonesty, Falsification, and Conduct Prejudicial to the Best Interest of the Service. Alonzo defended himself by claiming his records were lost due to a school revamp and a ransacking incident at the registrar’s office. He submitted affidavits from former school officials attesting to his graduation and the authenticity of his TOR. Notably, the National Police Commission (NAPOLCOM) had previously exonerated him in a separate but related case for lack of substantial evidence.

ISSUE

The primary issue is whether the Civil Service Commission correctly found Alonzo administratively liable for the charges, notwithstanding his defense and the prior exoneration by the NAPOLCOM.

RULING

The Supreme Court ruled in favor of the CSC, reinstating its decision finding Alonzo guilty. The Court clarified that the principle of res judicata does not apply, as the NAPOLCOM and the CSC are distinct bodies exercising different jurisdictions. The NAPOLCOM’s exoneration did not bar the CSC from pursuing its own administrative case, as the CSC possesses constitutional and statutory authority over all civil service matters, including those involving PNP members pertaining to their civil service eligibility and qualifications.
On the merits, the Court found substantial evidence to support the CSC’s finding of administrative liability. The verification from ACC’s current administration, which found no record of Alonzo’s graduation, directly contradicted his sworn representation in his PDS. His defense of lost records, supported by affidavits from former officials, was deemed insufficient to overcome the positive findings of the school’s official records custodian. The act of knowingly misrepresenting one’s educational attainment in an official document to secure a promotion constitutes Serious Dishonesty. This misrepresentation is intrinsically linked to Falsification of an Official Document and is unquestionably Conduct Prejudicial to the Best Interest of the Service, as it undermines the merit-based principles of the civil service. The penalty of dismissal from service was thus upheld as appropriate.