G.R. No. 206379 - Pagaduan vs. Civil Service Commission

Petitioner: Cecilia Pagaduan; Private respondent: Rema Martin Salvador (Municipal Budget Officer). Pagaduan filed a notarized complaint with CSC-Regional Office No. II (CSC-RO II) on May 14, 1992 charging Salvador with administrative falsification and misrepresentation for indicating in her Personal Data Sheet (PDS) that she performed bookkeeping and accounting for Veteran’s Woodworks, Inc. (VWI) from August 1, 1990 to February 15, 1992, when Pagaduan alleged Salvador was not employed by VWI.
Salvador’s defense was that she was employed under the management of Alfonso Tuzon, who supervised VWI logging operations, and that her name did not appear on VWI payrolls because Tuzon’s office operated independently.

On October 19, 1994 Pagaduan filed a criminal complaint for falsification of public documents (Article 172 in relation to Article 171(4), RPC) in MTCC (Criminal Case No. 15482). Proceedings culminated later in a separate criminal judgment (see below).
On May 22, 2000 the CSC-RO II rendered a decision in the administrative complaint finding Salvador liable only for Simple Misconduct and meting a penalty of one (1) month suspension as the act was considered an error of judgment. Pagaduan’s motion for reconsideration was denied; an appeal to the CSC was dismissed for lack of standing (Pagaduan was not the aggrieved party). CSC-RO II’s May 22, 2000 decision became final (order issued January 21, 2002) and Salvador served the one-month suspension.

On October 22, 2008 the MTCC rendered a decision (Criminal Case No. 15842) finding Salvador guilty of falsification of public documents. Salvador did not appeal and applied for probation, which was granted (probation is an admission of guilt for purpose of the Court’s analysis).
Pagaduan filed a second administrative complaint against Salvador alleging the offense of conviction of a crime involving moral turpitude based on the October 22, 2008 criminal conviction.

Salvador raised defenses including res judicata, forum shopping and double jeopardy, and filed counter-affidavit and supporting documents.
On January 12, 2010 the CSC-RO II found Salvador guilty of conviction of a crime involving moral turpitude (by reason of the MTCC conviction) and imposed the penalty of dismissal from the service with accessory penalties.
Salvador moved for reconsideration before the CSC; on March 1, 2011 the CSC reversed and set aside the CSC-RO II decision, exonerating Salvador and issuing a stern warning. The CSC held that falsification of public documents does not per se involve moral turpitude in Salvador’s case, treating her act as an error of judgment and relying on certain precedents (including Dela Torre and Zari).
Pagaduan’s motion for reconsideration to the CSC was denied on June 1, 2011.

Pagaduan appealed to the Court of Appeals (CA). On February 28, 2012 the CA reversed the CSC and affirmed the CSC-RO II decision, holding that a conviction for falsification of public document constitutes conviction of a crime involving moral turpitude (and noting the gravity of falsification in a PDS).
Salvador filed a motion for reconsideration in the CA. On August 31, 2012 the CA granted reconsideration and issued an Amended Decision reversing its February 28, 2012 decision and reinstating the CSC March 1, 2011 decision (thereby exonerating Salvador).
Pagaduan filed a petition for review under Rule 45 to the Supreme Court. The Supreme Court initially denied the petition (July 10, 2013) but later granted the motion for reconsideration (October 23, 2013), reinstating the petition. Parties filed comments and replies; the Supreme Court resolved the case by decision dated November 19, 2014.

Pagaduan sought review and reversal of the CA Amended Decision (Aug 31, 2012) and its Resolution (Feb 20, 2013) which exonerated Salvador.
The core assignments of error alleged that the CA erred in exonerating Salvador, erred in not applying Teves v. Sandiganbayan categorization of falsification as involving moral turpitude, and in not affirming CSC-RO II’s dismissal penalty.

Whether the second administrative complaint (conviction of a crime involving moral turpitude) was barred by res judicata or constituted forum shopping in view of the earlier administrative proceeding that resulted in a finding of Simple Misconduct.
Whether Salvador’s application for and grant of probation in the criminal case erased the conviction for purposes of administrative liability or otherwise barred administrative sanctions.

Whether Salvador’s conviction for falsification of public documents constitutes a conviction of a crime involving moral turpitude, thereby justifying dismissal from the government service with accessory penalties.