G.R. No. 198404 - San Felix vs. Civil Service Commission

Petitioner Melvin G. San Felix was charged by the Civil Service Commission (CSC) Regional Office No. 6 for allegedly committing dishonesty during the Police Officer I Examination held on March 29, 1998.
The charge stemmed from discrepancies noted by the CSC between the petitioner’s Personal Data Sheet (PDS) and the application documents—specifically, the differences in the picture and signature on the seat plan compared to those on his PDS.
The CSC alleged that these discrepancies indicated that San Felix had conspired with another person who took the examination on his behalf.

In his answer, petitioner denied any conspiracy or impersonation, maintaining that he personally took the examination.
He suggested that the differences in his documents could have resulted from a mix-up or the inadvertent interchange of pictures.
Petitioner filed a Motion to Dismiss, arguing that the CSC had been divested of the authority to conduct police examinations by virtue of a previous Supreme Court ruling in Civil Service Commission v. Court of Appeals.
The CSC Regional Office denied the motion and ordered the formal investigation to proceed.

On July 19, 2004, the CSC Regional Office rendered a decision finding petitioner guilty of dishonesty.

The decision imposed the penalty of dismissal from service.
Additionally, accessory penalties were ordered: disqualification from reemployment in the government service, cancellation of eligibility, forfeiture of retirement benefits, and a bar from taking any civil service examination.

The CSC subsequently issued its January 19, 2007 Resolution (Resolution No. 070100) affirming the Regional Office’s decision.

The CSC maintained that its actions—administering examinations and issuing eligibility—enjoyed the presumption of regularity until the Supreme Court’s decision in Civil Service Commission v. Court of Appeals.
Petitioner’s declaration in his PDS regarding his examination qualifications rendered him liable for falsification of documents under Article 171, paragraph 4 of the Revised Penal Code (RPC).

The Court of Appeals (CA) affirmed the decisions of the CSC without modifications concerning the substance of the charges, dismissing petitioner’s petition for review.
The CA held that although the Supreme Court ruling limited the CSC’s authority to administer police examinations, the CSC still retained jurisdiction to investigate anomalies and irregularities related to civil service examinations.
The CA further noted that petitioner was given ample opportunity to defend himself, and his failure to present additional evidence amounted to a waiver of his rights.

Republic Act No. 8551 (effective March 6, 1998) transferred the power to conduct and administer entrance and promotional examinations for police officers from the CSC to the National Police Commission (NPC).
Despite this transfer of authority, the CSC continued to have disciplinary jurisdiction over civil service matters, including the investigation of anomalies in the documents of civil servants, such as the PDS.
The CSC’s investigation was tied to its constitutional mandate to preserve the integrity of the civil service system.

The records indicated that petitioner allowed another person to take the Police Officer I Examination on his behalf, thereby procuring an eligibility under false pretenses.
By falsely claiming in his PDS that he had passed the examination, petitioner prejudiced other qualified applicants and violated the standards of integrity expected in the civil service.
The misconduct was deemed a deliberate act of dishonesty and falsification of an official document, as grounded in previous Supreme Court decisions and administrative jurisprudence.

Whether the CSC retained jurisdiction to investigate and discipline a civil servant for anomalies committed in an examination it no longer had the authority to conduct due to R.A. No. 8551 transferring that function to the NPC.
Whether the examination conducted on March 29, 1998, despite being without proper authority post the enactment of R.A. No. 8551, could serve as a basis for disciplinary action.

Whether petitioner’s act of allowing another individual to take the Police Officer I Examination constituted dishonesty and falsification of his PDS.
Whether petitioner was afforded due process in the investigation and subsequent administrative proceedings considering his failure to submit additional evidence at critical hearings.

Whether the loss of CSC’s authority to administer police examinations negated the penalties imposed on petitioner, particularly given the subsequent administrative findings of dishonesty.
Whether petitioner could benefit from the effects of an examination conducted without proper jurisdiction, especially after having acted in bad faith.