People vs. Benedictos - Falsification of Time Records

A.M. No. P-10-2784 (October 19, 2011)

Facts:

Ma. Emcisa A. Benedictos, an Administrative Officer I at the Regional Trial Court (RTC) in Malolos City, Bulacan, was charged with dishonesty for allegedly falsifying her Daily Time Records (DTRs) or bundy cards. The Office of the Court Administrator (OCA) initiated the inquiry after requesting her DTRs for September and October 2004. Benedictos submitted her bundy cards for August, October, and November 2004, which were then referred to Atty. Emmanuel L. Ortega, Clerk of Court VII, for verification of his signatures.

Atty. Ortega reported that only his signature on the November 2004 bundy card was genuine, disowning the signatures on the August and October cards. Despite being given multiple opportunities to respond to these allegations, including directives from the OCA and the Court, Benedictos failed to comply. The Court subsequently withheld her salaries and benefits until she submitted the required DTRs. After further non-compliance, the Court imposed a fine of P1,000.00 on her.

In August 2009, the Court deemed that Benedictos had waived her right to comment on the allegations against her. The OCA then recommended that she be found guilty of dishonesty and suggested a penalty of six months and one day suspension, considering it was her first administrative offense.

Legal Issues:

1. Whether Ma. Emcisa A. Benedictos was guilty of dishonesty for falsifying her DTRs.
2. What appropriate penalty should be imposed on her for the established offense.

Arguments:

• Prosecution (OCA): The OCA argued that Benedictos was guilty of dishonesty based on Atty. Ortega's disavowal of the signatures on her DTRs for August and October 2004. They highlighted her repeated failure to respond to the allegations and comply with the Court's directives, which they interpreted as an admission of guilt.

• Defense (Benedictos): Although Benedictos did not formally present a defense due to her non-compliance, her silence could be construed as a lack of opportunity to contest the allegations. The defense could argue that the penalties imposed were excessive given her long service in government and lack of prior offenses.

Court's Decision and Legal Reasoning:

The Court found Ma. Emcisa A. Benedictos guilty of dishonesty for falsifying her DTRs. The Court emphasized that her failure to respond to the allegations constituted an admission of guilt, as an innocent person would typically assert their innocence when accused. The Court noted the clear discrepancies between Atty. Ortega's genuine signatures and the purported ones on Benedictos's DTRs, which were easily discernible.

In determining the penalty, the Court recognized that dishonesty is a grave offense that could warrant dismissal from service. However, considering mitigating factors such as her long service of 19 years and the fact that this was her first administrative offense, the Court opted for a suspension of six months and one day. The Court also imposed an additional fine of P3,000.00 for her non-compliance with previous Court directives.

Significant Legal Principles or Doctrines Established:

1. Dishonesty Defined: The Court defined dishonesty as a disposition to lie, cheat, deceive, or defraud, which undermines the integrity of public service.
2. Admission by Silence: The failure to respond to serious allegations can be interpreted as an admission of guilt, particularly when the accused is given ample opportunity to contest the charges.
3. Mitigating Circumstances: The Court has the discretion to consider mitigating circumstances when imposing penalties for administrative offenses, which can lead to a lesser penalty than dismissal even for grave offenses.