Facts:

The case revolves around Ofelia D. Artuz, the petitioner, and the Court of Appeals, Civil Service Commission (CSC), and Rene A. Bornales, the respondents. The incident began on December 11, 1991, when Rene A. Bornales, a Legal Aide at the Regional Health Office No. VI (RHO VI) of the Department of Health (DOH), filed a Letter-Complaint against Ofelia D. Artuz, then a Legal Officer IV at RHO VI. Bornales accused Artuz of estafa through falsification of public documents. The filing of the complaint was compounded by an alleged delay in action by RHO VI, prompting Bornales to take his case to the Merit System Protection Board (MSPB) of the CSC. On November 10, 1992, the MSPB accepted the complaint and directed the CSC’s Regional Office No. VI to conduct an investigation.

Following an investigation, on May 28, 1993, the MSPB formally charged Artuz with dishonesty and falsification of public documents, asking her to respond within five days. In her defense, Artuz denied the allegati

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Facts:

Background and Initiation of Charges

• In December 1991, private respondent Rene A. Bornales, Legal Aide of Regional Health Office No. VI (RHO VI), filed a Letter-Complaint against petitioner Ofelia D. Artuz, then Legal Officer IV, alleging Estafa or Swindling through Falsification of Public Documents.
• Bornales’ complaint was purportedly motivated by vengeance after Artuz had previously filed a case against him for Gross Dishonesty, Grave Misconduct, Insubordination, and Conduct Prejudicial to the Best Interest of the Service.

Administrative Proceedings and Evidentiary Issues

• The Merit System Protection Board (MSPB) of the Civil Service Commission (CSC) took cognizance on 10 November 1992 and, on 28 May 1993, formally charged Artuz with Dishonesty and Falsification of Public Documents, directing her to file an answer within five days.
• In her answer, dated 20 July 1993, petitioner Artuz denied the charges, asserting that:
• The allegations were malicious, fabricated, and constituted pure harassment.
• She had dutifully performed her functions as a Legal Officer IV and regularly reported for duty as evidenced by her Daily Time Records (DTRs) for July and August 1991.
• The DTRs were duly verified by the Personnel Section and approved by the Director of RHO VI, and her Punch Cards would have confirmed her regular attendance.
• Artuz argued that the Logbook, cited later as the primary evidence of her attendance, was not mandated by any office memorandum or circular at the time, as the regional practice relied on the Bundy clock system and corresponding DTRs.

Subsequent Administrative and Appellate Resolutions

• On 24 August 1993, the CSC issued a resolution directing CSC Regional Office (RO) VI to conduct a formal investigation, emphasizing that “no fair and just decision can be made without the conduct of a formal investigation.”
• Following the investigation, CSC RO VI reported that substantial evidence existed demonstrating that Artuz had falsified her DTR entries for July and August 1991, with particular reliance on the Logbook as “the best evidence to prove the attendance of any employee.”
• On 9 December 1996, shortly after her appointment as Assistant City Prosecutor of Iloilo, Artuz received CSC Resolution No. 981650 (dated 26 June 1998) finding her guilty of dishonesty and imposing a penalty of dismissal with accessory penalties, which included cancellation of eligibility, forfeiture of leave credits and retirement benefits, and disqualification from re-employment in government service.
• Her subsequent Motion for Reconsideration (dated 30 July 1998, and later filings in 1999) was denied by both the CSC and the Court of Appeals, which on 29 September 1999 affirmed the dismissal, heavily relying on the evidentiary value of the Logbook despite the existence of her certified DTRs and the prevailing employment practices.

Evidentiary Controversies and Contentions

• The CSC and the Court of Appeals based the conviction primarily on the Logbook, assuming it to be the best evidence of attendance, a premise disputed by petitioner.
• Artuz maintained that:
• The DTRs, being duly certified and verified by the Personnel Section and the Regional Director, were more credible than the unsupervised Logbook entries.
• The common practice in 1991 involved using DTRs and Punch Cards (the latter being in the custody of the Personnel Section), rendering the absence of her personal Punch Cards non-detrimental to her case.
• A later memorandum dated 26 October 1994 required the use of both the Bundy clock and the Logbook; however, this policy change could not be retroactively applied to the incident in 1991.
• The evidence showed that the burden of proof rested on the complainant, Bornales, who failed to substantiate that the Petitioner's DTR entries were falsified based solely on the Logbook evidence.

Petitioner’s Relief and Court’s Intervention

• On 19 April 2000, Artuz filed a petition for review on certiorari before the Supreme Court against the administrative findings.
• Initially, on 4 July 2000, the petition was dismissed due to a finding of no grave abuse of discretion on the part of the Court of Appeals.
• A subsequent Motion for Reconsideration was eventually filed, wherein Artuz contended that the dismissal on a technical ground (i.e., the petition being filed under Rule 45 rather than Rule 65) and the heavy reliance on the Logbook were both erroneous.

Issue:

• Whether the filing of the Letter-Complaint by private respondent Bornales, apparently motivated by personal vendetta, was substantively valid.
• Whether the assumption that the Logbook is inherently “the best evidence to prove attendance” is correct, given the concurrent use of DTRs and the common practices in Region VI at the time.
• Whether the absence of petitioner Artuz’s submitted Punch Cards should be held against her, considering they were in the custody of the Personnel Section and not her direct responsibility.
• Whether the administrative proceedings adequately considered the probative value of DTRs over the Logbook and whether they established substantial evidence of falsification beyond reasonable doubt.
• Whether the late issuance of the memorandum (dated 26 October 1994), which mandated the use of the Logbook, can be applied retroactively to justify the finding of dishonesty in 1991.
• Whether the lower court and appellate tribunal erred in dismissing the petition on technicalities while relying solely on the Logbook evidence without reconciling it with the certified DTRs.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)