Title
Gonzalbo-Macatangay vs. Civil Service Commission
Case
G.R. No. 239995
Decision Date
Jun 15, 2022
A government employee's dismissal is upheld for bigamy, deemed a crime involving moral turpitude, despite arguments for mitigating circumstances.
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Case Digest (G.R. No. 239995)

Facts:

  • Rosa C. Gonzalbo-Macatangay (petitioner) faced a complaint from Marites L. Calivara regarding her marriage to Modesto Macatangay, Jr.
  • Marites alleged that the petitioner married Modesto on February 3, 1997, while he was still married to her.
  • A criminal case for Bigamy was filed against both the petitioner and Modesto in the Regional Trial Court (RTC) of Lucena City.
  • Both pleaded guilty, leading to their conviction, which became final on October 8, 2002.
  • The petitioner claimed ignorance of Modesto's existing marriage and stated she was coerced into marriage due to pregnancy.
  • The Civil Service Commission - National Capital Region (CSC-NCR) charged her with Conviction of a Crime Involving Moral Turpitude.
  • The CSC-NCR found her guilty and dismissed her from service on June 19, 2014, with penalties including cancellation of eligibility and forfeiture of retirement benefits.
  • The petitioner appealed to the CSC Proper, which affirmed the decision on January 5, 2015.
  • The Court of Appeals upheld this ruling on August 10, 2017, and denied her motion for reconsideration on May 9, 2018.
  • The petitioner subsequently filed a petition for review before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the petition was not meritorious and affirmed the decisions of the Court of Appeals and the Civil Service Commission.
  • ...(Unlock)

Ratio:

  • The Court noted that the petitioner did not contest her guilt regarding the administrative offense, which is classified as a grave offense punishable by dismissal upon first commission.
  • CSC Resolution No. 991936 states that such offenses warrant dismissal without the possibility of mitigation.
  • While mitigating circumstances can be considered, they must be properly invoked and justified; ...continue reading

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