A.M. No. P-07-2366 - Office of the Court Administrator vs. Flores

The Office of the Court Administrator (OCA) filed an administrative complaint charging Maria Celia A. Flores with dishonesty.
The charge stemmed from her failure to disclose, in her Personal Data Sheet (PDS), her previous suspension and dismissal from employment.

Flores was employed as Court Legal Researcher II at the Regional Trial Court, Branch 217, Quezon City, assuming office on 12 April 1994.
Prior to her judicial appointment, she worked for the Philippine Public School Teachers Association (PPSTA) from August 1973 until her termination in August 1990.
During her tenure at PPSTA, she:

Was involved in a brawl resulting in her dismissal.
Faced six separate administrative charges for misconduct, tardiness, absenteeism, and violations of office rules.
Had a suspension in 1977 for fifteen (15) days due to misconduct and other related offenses.

In 2006, the OCA discovered through a labor case (G.R. No. 109362, promulgated on 15 May 1996) that Flores was involved in prior administrative proceedings.
The labor case showed that:

Flores filed a complaint for illegal dismissal which initially ruled in her favor at the Labor Arbiter level.
On appeal, the National Labor Relations Commission (NLRC) upheld her dismissal.
Flores escalated the matter to the Supreme Court via a petition for certiorari.

Despite the apparent significance of these facts, her PDS did not reflect the details of her suspension or the administrative charges.

The PDS, required under Civil Service Rules for government employment, contained specific questions regarding:

Having a pending petition for certiorari (related to her dismissal).
The requirement to provide full particulars regarding her administrative record.

A later PDS, accomplished on 6 February 2007 for a lateral transfer, showed full disclosure of her prior suspension, administrative charges, and dismissal, highlighting the discrepancy.

Upon learning of the labor case, the OCA sought Flores’ 201 File and, lacking the PDS, obtained a copy from the Civil Service Commission.
Based on the evidence, in a 1st Indorsement dated 3 January 2007, the OCA directed Flores to explain the omission of her prior suspension and dismissal.
Flores defended herself by claiming that her failure to disclose was due to “human frailty” and an “honest mistake,” reasoning that the suspension, occurring over seventeen years earlier, might have been inadvertently forgotten.
She also contested the investigation process by alleging partiality on the part of the investigating Court Administrator.

On 4 May 2007, the OCA found Flores guilty of dishonesty and recommended her dismissal based on the evidence of concealment.
After the parties complied with subsequent procedural requirements, the Court adopted the OCA’s findings.
The court noted that the omission was not a mere oversight but an intentional act of concealment, which undermined the integrity required in government service.

Did Flores intentionally conceal material facts regarding her prior suspension and administrative charges?
Is referencing a pending petition for certiorari sufficient to satisfy the requirement for full disclosure under the PDS?

Whether the procedures followed by the OCA were proper in initiating and conducting the investigation.

Was the OCA justified in relying on the records procured from the Civil Service Commission due to the absence of the original PDS on file?
Did the investigative actions and subsequent indorsement adhere to due process given the allegations of partiality raised by Flores?