A.M. No. P-17-3710, P-18-3822 - Office of the Court Administrator vs. Bravo

The case consolidates administrative proceedings against Vladimir A. Bravo, Court Interpreter II of the Metropolitan Trial Court, Manila, Branch 24, concerning his habitual absenteeism.
The Office of the Court Administrator (OCA) initiated administrative actions based on repeated unauthorized absences.

A letter dated December 11, 2012, by Teodora R. Balboa, Branch Clerk of Court, reported that Bravo had been absent since September 19, 2012, without filing any leave of absence.
The OCA issued a first indorsement on June 19, 2013, directing Bravo to submit a comment regarding the report of his habitual absence.
Bravo failed to respond to the initial directive, prompting a follow-up tracer on April 23, 2014.
A second directive was issued on July 15, 2013, again instructing him to explain his actions.
Bravo once more did not comment and eventually tendered his resignation effective August 23, 2013, instead of addressing the charges.

Total unauthorized absences computed to 133.5 days, significantly exceeding the lawful standards.

The OCA interpreted Bravo’s silence as tacit admission to the misconduct.
Certifications from the Leave Division of the Office of Administrative Services (OAS) corroborated the record of his unauthorized absences.
The resignation was viewed as an evasive tactic aimed at forestalling the imposition of regular administrative penalties while preserving potential re-employment prospects.
The initial administrative matter was re-docketed as a regular administrative case after the Court En Banc consolidated the matters under A.M. Nos. 13-7-62-MeTC and 13-6-44-MeTC.

Whether Vladimir A. Bravo is guilty of habitual absenteeism as defined under the applicable Civil Service rules.
Whether Bravo’s failure to respond to directives and his voluntary resignation should be interpreted as an admission of guilt regarding unauthorized absences.
Whether the total number of absences exceeds the allowable limit (2.5 days per month) that would constitute habitual absenteeism.
Whether the appropriate penalty should include dismissal from service, forfeiture of retirement benefits (save for accrued leave credits), and barring from re-employment in any government agency.