Title
Maniebo vs. Court of Appeals
Case
G.R. No. 158708
Decision Date
Aug 18, 2010
Justina Maniebo, appointed as Cashier III, was dismissed for falsifying her civil service exam rating. Appeals denied due to procedural noncompliance and lack of evidence for good faith. Supreme Court upheld dismissal, emphasizing mandatory procedural rules and gravity of dishonesty.

Case Summary (A.M. No. MTJ-95-1062, MTJ-00-1260)

Factual Background and Administrative Actions

The petitioner was promoted in 1994 to a permanent position as Cashier III based on her purported possession of a Career Service (Professional) Eligibility with a rating of 74.01% from the 1983 examination. Upon verification, the CSC discovered the petitioner actually obtained only 60%, meaning she had failed the exam. Consequently, the CSC Regional Office (CSCRO) No. IV initiated a preliminary investigation and formally charged her with possession of a spurious report of rating, falsification, grave misconduct, and dishonesty in October 1997. She denied knowledge of the falsified eligibility certificate, claiming it was received by mail without her intervention. After hearings, CSCRO No. IV found her guilty and imposed dismissal from the service in December 1999. The CSC affirmed this penalty in March 2002 and denied her motion for reconsideration in August 2002.

Procedural History in the Court of Appeals

Petitioner appealed to the Court of Appeals (CA), which dismissed her petition for review due to her failure to submit the requisite certified true copies of material portions of the record as mandated by Section 6 and Section 7, Rule 43 of the Rules of Court. She initially moved for reconsideration and undertook to submit the required documents within ten days, but ultimately failed to comply. The CA denied her motion for reconsideration, citing the untimeliness and her failure to rectify procedural defects. She filed a second, prohibited motion for reconsideration, which the CA also denied. Aggrieved, she elevated the case to the Supreme Court by petition for review on certiorari.

Issues Presented for Resolution

  1. Whether the CA committed reversible error in dismissing the petition for review based on the alleged failure to attach certified true copies of annexes, when according to petitioner rules and jurisprudence do not require certification for all annexes.
  2. Whether the CA erred in dismissing the petition for review over alleged technicalities that were not sanctioned by jurisprudence.

Supreme Court’s Ruling on Procedural Compliance

The Supreme Court found no reversible error in the CA’s dismissal. It emphasized that Section 6, Rule 43 of the Rules of Court explicitly requires petitions for review to be accompanied by certified true copies of the challenged decision and all material portions of the record necessary for the appellate court’s resolution. This requirement ensures that the CA can immediately determine whether to give due course to the petition. The petitioner’s partial certification of documents did not meet the “substantial compliance” threshold, particularly since she failed to submit a certified copy of the pivotal CSC Resolution No. 02-0433, which imposed the penalty of dismissal. Further, her failure to honor her undertaking to provide the omitted documents within the given period compounded the non-compliance.

The Court clarified that although some jurisprudence states that only the final order or judgment needs certification, such rulings still require substantial compliance, especially when the appeal challenges multiple resolutions. The petitioner also failed to indicate the date of receipt of the CA’s resolution dismissing her petition, a necessary detail to evaluate the timeliness of her motion for reconsideration.

Additionally, her second motion for reconsideration violated Rule 52, Section 2 of the Rules of Court, which prohibits filing a second motion for reconsideration of the same resolution. The Court ruled that the procedural rules must be strictly followed, as disregarding these would reduce the rules to mere trifles, thereby potentially undermining judicial discipline and process.

Supreme Court’s Analysis on Merits of the Case

Although the Court’s ruling hinged on procedural grounds, it nonetheless examined the substantive issues. The petitioner’s claim of good faith in possessing the falsified eligibility was rejected. The Court held that the presumption of innocence in good faith possession does not apply when official records, such as the CSC Masterlist of Eligibles, show otherwise. The petitioner failed to present credible evidence, such as postmaster certification proving the spurious certificate was merely mailed to her, and her denial was insufficient to rebut the presumption of forgery or procurement of the false document.

Relying on precedent, the Court emphasized that the actual CSC records prevail over the self-serving claims of an employee. Possession and use of a fraudulent eligibility document warranted dismissal due to dishonesty and falsification.

Applicability of Republic Act No. 6850 to the Petitioner’s Case

The petitioner argued that even if she lacked civil service eligibility upon employment, she should be considered eligible by operation of law under Republic Act No. 6850, which grants eligibility to temporary or provisional employees who have rendered at least seven years of efficient service. The Supreme Court rejected this argument, clarifying that R.A. 6850 does not automatically convert temporary appointments into permanent ones upon acquisition of eligibility. The CSC must still evaluate the e

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