Title
Supreme Court
Office of the Court Administrator vs. Pedrina
Case
A.M. No. P-16-3471
Decision Date
Jul 26, 2016
A court clerk, previously penalized for habitual tardiness, was dismissed after repeated offenses despite citing health issues, lacking medical proof.

Case Summary (G.R. No. 153205)

Summary of Recommendations

The case was considered on the recommendations of the OCA, which suggested that the matter against John Revel B. Pedriaa be re-docketed as a regular administrative case. The OCA specifically found Pedriaa guilty of habitual tardiness for the third time and recommended his dismissal from service, including forfeiture of retirement benefits except for accrued leave credits, with prejudice to re-employment in government service.

Facts of the Case

A report dated May 26, 2015, indicated that Pedriaa incurred numerous instances of tardiness throughout various months in 2014, with a total of 82 instances across January, February, March, May, July, September, November, and December. The OCA received records of these incidents through Pedriaa's timecards. Follow-up communication from OCA chief Caridad A. Pabello prompted further review, and by June 26, 2015, a request was made for Pedriaa to comment on the allegations. Pedriaa acknowledged his tardiness, attributing it to health issues, including severe headaches and anemia, which he claimed affected his ability to rise early and travel to work.

Respondent’s Defense

In response to the allegations, Pedriaa cited his health problems as the causes for his habitual tardiness. He apologized, expressed that he was increasing his work output to make up for the tardiness, and committed to improving his punctuality. However, the OCA observed that he failed to provide credible medical evidence supporting his claims about serious health issues affecting his work attendance.

The Court's Ruling

The Court granted the OCA's recommendations, recognizing Pedriaa's persistent tardiness. Citing Civil Service Memorandum Circular No. 23, Series of 1998, the Court defined habitual tardiness as incurring tardiness at least ten times in a month for two consecutive months. The Court emphasized that government employees must maintain punctuality due to the public trust vested in them.

Compliance with Standards of Conduct

The Court reiterated the elevated standards of ethics and conduct expected from all court employees, as previously expressed in Basco v. Gregorio, stressing that all judiciary personnel must exemplify integrity and diligence. Respondent Pedriaa's justifications for his tardiness were dismissed as insufficient, reiterating that personal and health-related issues do not excuse habitual tardiness as established by existing jurisprudence.

Prior Penalties and Disciplinary Measures

Notably, this was not Pedriaa's first infra

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