Title
Momongan vs. Sumayo
Case
A.M. No. P-10-2767
Decision Date
Apr 12, 2011
Primitivo Sumayo, RTC Clerk III, dismissed for Gross Dishonesty and Falsification of Public Document after misrepresenting educational qualifications and civil service eligibility, undermining judicial integrity.

Case Summary (A.M. No. P-10-2767)

Background of the Complaint

The complaint against Sumayo was initiated on October 11, 2007, and was subsequently supported by an anonymous letter that also raised similar concerns. The allegations specified that Sumayo forged his civil service eligibility and misrepresented his educational status, claiming to have graduated from college despite lacking some credits in accounting. Sumayo contended that he completed his major in banking and finance and that the University of Visayas allowed him to graduate despite having incomplete grades.

Investigation Process

After the complaints were lodged, the Office of the Court Administrator (OCA) contacted the University of Visayas to confirm Sumayo's graduation status; however, the university did not respond to the inquiry. The investigation, led by Judge Meinardo P. Paredes of the RTC Cebu, involved a hearing on November 22, 2010, where both the complainant and respondent provided testimony. Sumayo's reliability was further questioned when he was unable to provide the documentation requested by the investigating judge, including proof of his civil service eligibility and his Personal Data Sheet (PDS).

Findings and Recommendations

The investigating judge noted that Sumayo failed to produce the necessary documentation to substantiate his educational claims and civil service eligibility. Instead, he submitted a Manifestation insisting that it was the complainant's responsibility to produce evidence, thus failing to address the allegations adequately. The investigating judge’s report recommended Sumayo’s dismissal due to the findings of dishonesty and misrepresentation.

Court's Decision

The court accepted the findings and recommendations of the investigating judge, concluding that Sumayo's failure to provide adequate proof of his qualifications indicated dishonesty regarding his academic and civil service credentials. It was established that Sumayo had indeed misrepresented himself in securing his position, which is deemed a serious offense within the context of government service, particularly in a sensitive role within the judiciary.

Legal Principles Involved

The court referenced Section 52, Rule XIV of the Omnibus Rules Implementing Book V of Executive Order No. 292, which classifies offenses suc

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