Case Summary (A.M. No. P-17-3710, P-18-3822)
Factual Antecedents
Bravo's absenteeism emerged prominently when Teodora R. Balboa, the Branch Clerk of Court at MeTC, wrote to the OCA on December 11, 2012, requesting acknowledgment of Bravo as Absent Without Official Leave (AWOL) due to his continuous absence since September 19, 2012, without a recorded leave. The OCA subsequently issued a directive on June 19, 2013, requesting Bravo’s commentary on the report, which he failed to submit. Additional communications, including a tracer dated April 23, 2014, yielded no response from Bravo, who instead chose to resign from the judiciary effective August 23, 2013.
Report and Recommendation of the Office of the Court Administrator
In its report dated February 9, 2017, the OCA concluded that Bravo’s failure to respond indicated an implicit admission to the charges of habitual absenteeism. He had a substantial history of unauthorized absences: totaling 72.5 days in 2012 and 61 days in 2013. The OCA emphasized that such actions posed a threat to the integrity of the judiciary and recommended dismissing Bravo with accessory penalties preventing his future employment in any government entity due to the severity of his infractions.
Issue
The central issue for determination was whether Bravo’s conduct constituted habitual absenteeism warranting dismissal and barring him from future government service.
The Court's Ruling
The Court upheld the OCA's findings, categorizing Bravo’s actions as habitual absenteeism, which is defined under Civil Service regulations as exceeding permissible leave credits consistently over a specified period. Bravo’s unauthorized absences significantly surpassed the allowable threshold. The Court highlighted that his silence and failure to provide an explanation served as aggravating factors, suggesting deliberate avoidance of accountability. Thus, the Court held that allowing his return to public service would compromise the integrity of the judiciary, reinforcing the
...continue readingCase Syllabus (A.M. No. P-17-3710, P-18-3822)
Factual Antecedents
- The case revolves around the habitual absenteeism of Vladimir A. Bravo, a Court Interpreter II at the Metropolitan Trial Court (MeTC), Branch 24, Manila.
- Teodora R. Balboa, the Branch Clerk of Court, reported Bravo's continuous absences to the Office of the Court Administrator (OCA) on December 11, 2012.
- Bravo was deemed to be Absent Without Official Leave (AWOL) since September 19, 2012, without any filed leave of absence.
- The OCA issued a 1st Indorsement on June 19, 2013, requesting Bravo to comment on the report of his absences, but he failed to do so.
- A follow-up Tracer was sent on April 23, 2014, yet Bravo did not respond.
- Additionally, on July 15, 2013, Bravo was directed to comment on a second violation, but he again did not comply.
- Instead of responding, Bravo resigned from his position on August 23, 2013.
Unauthorized Absences Documented
- Bravo's absences were meticulously documented, revealing significant unauthorized absences in 2012 and 2013.
- In 2012, he incurred a total of 72.5 unauthorized absences over several months:
- September: 20 days
- October: 21.5 days
- November: 19 days
- December: 12 days
- In 2013, he accumulated 61 unauthorized absences