G.R. No. 177191 - San Juan y Cruz vs. People

On March 15, 2011, Executive Judge Jaime L. Infante of the RTC of Alabel, Sarangani Province, Branch 38, sent a letter to the Office of the Court Administrator (OCA) inquiring about the employment status of Sarah P. Ampong, Court Interpreter III since August 3, 1993.
The letter disclosed that despite Ampong’s dismissal by the Civil Service Commission (CSC) – which had been affirmed by the courts – the RTC continued to employ her, and she had been receiving her monthly salary and benefits.

In August 1994, the CSC initiated an administrative case against Ampong, charging her with Dishonesty, Grave Misconduct, and Conduct Prejudicial to the Best Interest of the Service.
The case arose from her act of impersonating or taking the November 1991 Civil Service Eligibility Examination for Teachers on behalf of Evelyn B. Junio-Decir.
On March 21, 1996, after Ampong admitted to the charges, the CSC rendered a resolution dismissing her from service, imposing accessory penalties, and revoking her Professional Board Examination for Teachers (PBET) rating.

Ampong moved for reconsideration, arguing that her appointment to the judiciary had taken place before the filing of the case, thereby removing the CSC’s jurisdiction over her.
Her motion for reconsideration was denied, prompting her to file a petition for review before the Court of Appeals (CA), which on November 30, 2004, denied her petition and affirmed her dismissal.
Subsequently, on August 26, 2008, the Court En Banc, in G.R. No. 167916, again denied her petition for review on certiorari and upheld the dismissal.

Despite her dismissal, the Financial Management Office (FMO) of the OCA continued to release Ampong’s salaries and allowances because the RTC had not received any official directive regarding her dismissal.
Following the notification from Judge Infante, the FMO, on September 7, 2011, issued a memorandum to the OCA instructing that Ampong’s salaries and allowances be withheld starting June 2011.

On March 27, 2013, the OCA issued a memorandum recommending that Ampong be found guilty of Dishonesty for impersonating and taking the civil service examination on behalf of Decir.
The OCA argued that her act of impersonation, regardless of its connection (or lack thereof) with her official functions or the timing of the offense relative to her judicial appointment, warranted dismissal.
The memorandum emphasized that the CSC retained the power to discipline employees in all government branches, including the judiciary, to uphold the integrity of the civil service.
It further detailed that the dismissal would carry accessory penalties such as cancellation of civil service eligibility, forfeiture of retirement and other benefits (except accrued leave credits), and perpetual disqualification from re-employment in government service.

Whether or not Sarah P. Ampong, Court Interpreter III of the RTC of Alabel, had been validly dismissed from her employment despite the continued receipt of salary and benefits.
Whether the argument that the CSC lacked jurisdiction over Ampong—given her later appointment to the judiciary—barred the imposition of the administrative penalty.