Case Summary (A.C. No. 4863)
Antecedents
The CSC established that Camsol requested the authentication of her eligibility based on her claim of passing the Career Service Professional Examination on September 16, 2002. However, it was revealed that no such examination took place on that date in Baguio City. In fact, Camsol had failed the relevant examinations held on May 2 and October 17, 2002. She subsequently received a spurious Certificate of Eligibility from an individual named Allan, whom she claimed misled her. The CSC formalized charges against Camsol, to which she responded by denying the accusations.
Ruling of the CSC
On October 4, 2016, the CSC issued its ruling upholding the findings of the CSC-Cordillera Administrative Region, affirming Camsol's guilt and imposing the penalty of dismissal from public service. The CSC determined that Camsol's possession of a fake eligibility certificate constituted Grave Misconduct and Serious Dishonesty, undermining the integrity of the civil service. This led to ancillary penalties including the forfeiture of retirement benefits and a perpetual disqualification from holding public office.
Ruling of the Court of Appeals
Upon Camsol's appeal, the Court of Appeals (CA) wholly affirmed the CSC's decision. The CA noted that the procurement of the spurious Certificate of Eligibility amounted to serious wrongdoing. The court emphasized that even a first-time offender could face dismissal for such grievous offenses, arguing that mitigating circumstances were irrelevant given the severe nature of Camsol's actions.
Issue
The central issue on appeal was whether the CA wrongly adjudged Camsol guilty of Grave Misconduct, Serious Dishonesty, and Conduct Prejudicial to the Service without taking into account any mitigating circumstances that favored her case.
Ruling of the Court
The Supreme Court partially granted the petition. While the Court acknowledged the CA's findings regarding the legitimacy of the charges against Camsol, it disagreed with the severe penalty of dismissal. The Court observed that Camsol did not benefit from the fraudulent certificate and had maintained a lengthy, unblemished service history in the government, serving over thirty years without any prior complaints. Furthermore, the Court considered that this was Camsol's first offense and that she had reached the threshold of her retirement age.
Penalties: Ultimately, the Supreme Court delivered a modified r
...continue readingCase Syllabus (A.C. No. 4863)
The Case
- This case involves a petition filed by Teresita M. Camsol against the Civil Service Commission (CSC) contesting the decision made by the Court of Appeals (CA) on February 13, 2018.
- The CA's decision affirmed the CSC's earlier ruling on October 4, 2016, which found Camsol guilty of Grave Misconduct, Serious Dishonesty, and Conduct Prejudicial to the Best Interest of the Service.
Antecedents
- Camsol served as a Forest Technician II at the Department of Environment and Natural Resources (DENR) in Buguias, Benguet.
- She requested the authentication of her Career Service Professional Eligibility from CSC-Cordillera Administrative Region (CSC-CAR), asserting she passed the Career Service Professional Examination on September 16, 2002, with a rating of 82.10.
- The CSC-CAR revealed that no examination took place on that date and that Camsol had previously failed the examinations on May 2 and October 17, 2002, receiving a rating of 48.08 each time.
- Camsol claimed to have received a fraudulent Certificate of Eligibility (COE) from an individual named Allan, whom she alleged deceived her into believing the COE was genuine after she paid him P100.00.
Ruling of the CSC
- On February 5, 2016, CSC-CAR found Camsol guilty of Grave Misconduct, Serious Dishonesty, and Conduct