G.R. No. 132577 - People vs. Webb

Three anonymous letters were received, allegedly from disgruntled employees of the Regional Trial Court (RTC) of San Fernando, Pampanga.
The letters accused respondent Lyndon L. Isip, Sheriff IV of the said court, of falsifying his Daily Time Record (DTR) by punching in at a location other than his official work station.
It was alleged that respondent manipulated his time record by having his DTR punched in at the RTC in Guagua, where his wife is employed, to avoid being late.

Respondent was accused of routinely bringing his DTR home after office hours.
He would then punch it in the bundy clock located at RTC-Guagua the following morning before proceeding to his official work station at RTC-San Fernando.
This practice resulted in discrepancies between the actual time of arrival (as recorded in the logbook) and the time reflected on his DTR.

Witnessed respondent’s arrival on 22 November 2004 at the RTC-San Fernando, where he did not punch in the DTR on the bundy clock immediately.
Confronted respondent, who then admitted to punching in at the RTC-Guagua.

Confirmed that the Office of the Clerk of Court (OCC) logbook included a record indicating respondent’s DTR was missing initially.
Noted that the recorded time in the DTR did not match the actual clock-in time recorded in the logbook.

Explained that multiple bundy clocks set at different intervals often led to irregularity in reported times.
Mentioned that employees sometimes forgot or deliberately did not log in their actual arrival time, creating non-consecutive logbook entries.

The logbook of the OCC, RTC-San Fernando, was examined to compare respondent’s reported work hours with his actual time of entry.
Evidence showed that respondent began this practice on 11 October 2004, recording times that did not align with his actual arrival at his designated office.
Observations indicated that the logbook entries for respondent’s time of arrival were inconsistent, coming in earlier than expected relative to preceding employees.
Respondent’s own admission during investigation corroborated his practice of punching in at RTC-Guagua.

The discrepancies in the record confirmed that respondent falsified his DTR by timing in at a location other than his official work station.
Despite the gravity of the offense (dishonesty), the investigating judge found mitigating circumstances:

Respondent had been in service for many years with no previous offense.
He continuously arrived before 8:00 AM, indicating that even the falsified entry did not make him tardy.
His admission of wrongdoing and expression of remorse were significant.

Based on these factors, the Investigating Judge recommended a penalty of suspension for one year without pay, instead of dismissal.

The OCA agreed that respondent’s conduct fell short of the required standards of public office.
They reiterated that his act of punching in at RTC-Guagua was a violation of OCA Circular No. 7-2003, which mandates that employees record the “truthful and accurate” time of arrival at their official work station (RTC-San Fernando in this instance).
The OCA noted the mitigating circumstances (first offense, more than 12 years of service, and promise to reform) and hence, recommended a penalty less severe than dismissal.
Ultimately, the OCA adopted the penalty recommendation of the Investigating Judge.

Whether the respondent’s act of punching in his DTR at RTC-Guagua, instead of his official work station at RTC-San Fernando, constitutes a falsification of time records.
Determining if such falsification as a deliberate act amounts to dishonesty under applicable civil service rules.

Whether the clear mandate of accurately recording the time of arrival at the official work station was breached by the respondent.
The implications of such a breach in terms of administrative liability and accountability.

The impact of factors such as the respondent’s long service record, his prior unblemished record, and his prompt admission of the misconduct.
Whether the existence of mitigating circumstances justifies imposing a lighter penalty in administrative cases of dishonesty, as evidenced by previous jurisprudence.