A.M. No. 06-12-720-RTC

Godofredo C. De Leon, then Utility Worker I, was offered a promotional appointment to Clerk III at the Regional Trial Court, Branch 40, Manila.
The appointment was forwarded on September 16, 2005, to the Civil Service Commission (CSC) for approval in accordance with applicable Civil Service laws and regulations.

In support of his promotional appointment, the respondent submitted a Personal Data Sheet (PDS) dated April 8, 2005, which stated that he was a Career Service Sub-Professional eligible.
He also submitted a Report of Rating allegedly issued by the CSC showing that he passed the Career Service Sub-Professional examination on November 20, 1977, with a rating of 78.77%.
A certification from the Integrated Records Management Office, CSC-CO, revealed that the respondent’s name did not appear on the Passed/Failed Masterlist of eligibles.
It was discovered that the eligibility claimed actually belonged to his brother, Reynaldo C. De Leon, and that the Report of Rating he submitted had been tampered with, as it carried his brother’s information.

On November 25, 2005, the Office of the Court Administrator (OCA) directed the respondent to show cause why no disciplinary action should be taken against him for falsification and misrepresentation.
Initially, the respondent did not file any comments even after requesting an extension of time.
Subsequently, on November 20, 2006, the CSC filed a Formal Charge for Dishonesty against him.
In compliance with the CSC’s directive, he filed a counter-affidavit stating:

The inclusion of his brother’s Career Service Sub-Professional eligibility was inadvertent.
He claimed that he did not tamper with his brother’s Report of Rating but merely carelessly submitted it along with his own documents.
He only became aware of the error a week after the submission of his application papers to the Supreme Court.

After further directives, the respondent submitted his Explanation/Comment on May 4, 2007, wherein he eventually admitted that he had changed the name of his younger brother Reynaldo to Godofredo in the authenticated CSC Report of Rating.
He pleaded for mercy, attributing his misdeed to his desire to secure promotion for the welfare of his family.

A resolution dated September 26, 2007, referred the matter to the OCA and the Chairperson, Selection and Promotion Board, Lower Courts, for evaluation and recommendation.
A memorandum dated January 4, 2008, prepared for Chief Justice Reynato S. Puno by Court Administrator Zenaida N. ElepaAo, found the respondent guilty of Dishonesty and Falsification of Official Document.
It was recommended that he be dismissed from the service with the forfeiture of all retirement benefits (except accrued leave credits) and that his dismissal be with prejudice to any future reemployment in any government office.

The Code of Conduct and Ethical Standards for Public Officials and Employees underscores the need for high standards of integrity, probity, and honesty in public service.
The case references Civil Service Commission v. Sta. Ana, which involved a similar incident of submitting a spurious Certificate of Eligibility and resulted in the dismissal of the respondent for dishonesty and falsification of public documents.

Whether the respondent’s submission of falsified documents, including the tampered Report of Rating that belonged to his brother, constitutes grounds for dismissal under the rules governing Civil Service appointments.
Whether the respondent’s claim of inadvertence and his subsequent plea for leniency due to his family’s welfare can be considered mitigating circumstances sufficient to forestall dismissal.
Whether the rules and established ethical standards in the judiciary, which require absolute integrity and honesty, allow for any leniency in cases involving the falsification of official documents.