Facts:

The case involves Sarah P. Ampong (petitioner) and the Civil Service Commission (CSC), specifically its Regional Office No. XI in Davao City (respondent). On November 10, 1991, a Professional Board Examination for Teachers (PBET) was conducted in Davao City, attended by a candidate named Evelyn Junio-Decir, who passed the examination with a score of 74.27%. At that time, both Ampong and Decir were public school teachers under the Department of Education, Culture and Sports (DECS). On August 3, 1993, Ampong transferred to the Regional Trial Court (RTC) in Alabel, Sarangani Province, where she assumed the position of Court Interpreter III.

On July 5, 1994, an individual claiming to be Evelyn Decir appeared at the CSC Regional Office No. XI to secure her eligibility certificate. However, the staff noticed a discrepancy between the individual’s appearance and the photograph on file. Subsequent investigation revealed that it was actually Ampong who had taken the PBET under Decir’s n

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Facts:

Background and Examination

• On November 10, 1991, the Professional Board Examination for Teachers (PBET) was held in Davao City.
• A certain Evelyn Junio-Decir applied for and took the examination at Room 16, Kapitan Tomas Monteverde Elementary School and passed with a rating of 74.27%.
• At that time, both Sarah P. Ampong (née Navarra) and Evelyn Decir were public school teachers under the supervision of the Department of Education, Culture and Sports (DECS).

Transfer and Judicial Appointment

• On August 3, 1993, Ampong transferred to the Regional Trial Court (RTC) in Alabel, Sarangani Province.
• She was appointed as Court Interpreter III, marking her entry into the judiciary.

Discovery of the Anomaly in the Examination Records

• On July 5, 1994, a woman claiming to be Evelyn Decir appeared at the Civil Service Regional Office (CSRO) No. XI, Davao City to claim her PBET Certificate of Eligibility.
• CSRO personnel observed that the individual’s appearance did not match the picture in the Picture Seat Plan (PSP) and further investigation revealed a marked discrepancy with the corresponding civil service records.

Preliminary Investigation and Formal Charges

• Initial investigation by the CSRO established a prima facie case against both Decir and Ampong for Dishonesty, Grave Misconduct, and Conduct Prejudicial to the Best Interest of the Service.
• On August 23, 1994, formal charges were filed indicating:

- That prior to the PBET, Evelyn B. Junio (later Decir) took the examination with a passing rate. - That on July 5, 1994, discrepancies were noted in the identification documents, photographs, and signatures. - That further inquiry disclosed that the actual examinee was Sarah P. Ampong, who impersonated Decir. - That the acts constituted dishonesty and other irregularities by subverting the integrity of civil service examinations.

Responses and Admissions of the Accused

• Evelyn Decir, in her sworn statement dated November 3, 1994, denied the charges, attributing the discrepancies to possible errors by the examination proctor and explaining the variation in her signature due to still using her maiden name.
• Sarah P. Ampong:

- Voluntarily appeared at the CSRO on February 2, 1995, where she admitted to the wrongdoing without initially seeking counsel. - On March 13, 1995, she made an oral admission of guilt, confirming that she had impersonated Decir and waived her right to counsel. - Reiterated her admission in her sworn Answer dated March 16, 1995, explaining that she was persuaded by a relative to help out, that she was unaware the act was subject to disciplinary sanctions, and that her generally exemplary conduct and personal background were not excuses for the misconduct.

CSC Findings and Penalty Imposed

• On March 21, 1996, the Civil Service Commission (CSC) found both Ampong and Decir guilty of dishonesty.
• The CSC imposed the penalty of dismissal with all accessory penalties, and, in Decir’s case, revoked the PBET rating.

Motion for Reconsideration and Jurisdictional Issue

• Ampong filed a motion for reconsideration wherein she raised, for the first time, the issue of jurisdiction.

- She argued that the exclusive authority to discipline judicial employees lies with the Supreme Court. - She contended that as she had assumed duty as a judicial employee (appointed on August 3, 1993), the CSC had overstepped its jurisdiction by proceeding with disciplinary actions.

Appeal to the Court of Appeals (CA)

• Ampong appealed the CSC decision before the CA, insisting that her status as a judicial employee placed her under the exclusive disciplinary authority of the Supreme Court.
• The CA, in its Decision dated November 30, 2004, held that:

- Ampong’s active participation and admissions during the CSC proceedings estopped her from later contesting the CSC’s jurisdiction. - Despite her judicial appointment, her acts committed prior to the transfer and the nature of her misconduct subject her to the CSC’s administrative jurisdiction as part of the civil service.

Issue:

Jurisdictional Authority

• Whether the Civil Service Commission properly assumed jurisdiction over the administrative proceedings against a judicial employee for acts of dishonesty committed prior to her appointment to the judiciary.
• Whether the exclusive authority to discipline judicial employees, as purported by the petitioner, should preclude the CSC from exercising administrative jurisdiction.

Timing of the Offense and Determination of Jurisdiction

• Whether the point in time at which the offense was committed (while Ampong was still under the DECS) is material in determining which body (CSC or Supreme Court) has jurisdiction once the proceedings are instituted.

Effect of the Petitioner’s Participation

• Whether Ampong’s full participation in the CSC proceedings, including her voluntary admission of guilt and waiver of her right to counsel, estops her from later disputing the commission’s jurisdiction over her case.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)