**Facts**:
1. On July 1, 1994, Justina Maniebo was promoted to Cashier III by the Mayor of Puerto Galera, Oriental Mindoro. The promotion was based on her Personal Data Sheet which listed a Career Service (Professional) Eligibility with a rating of 74.01% from an exam on July 17, 1983.
2. However, verification against the Masterlist of Eligibles revealed Maniebo actually failed the exam with a rating of 60%.
3. CSC Regional Office IV (CSCRO-IV) conducted a preliminary investigation and found a prima facie case against Maniebo for possession of a falsified report, falsification, grave misconduct, and dishonesty. Formal charges were filed on October 28, 1997.
4. Maniebo responded on November 7, 1997, but her response was deemed unsatisfactory, leading to scheduled hearings.
5. During hearings, Maniebo denied knowledge of the falsification, claiming that the rating document arrived via mail and that she had no dealings with CSC personnel to procure a false rating.
6. On December 16, 1999, CSCRO-IV found Maniebo guilty and dismissed her from service.
7. Maniebo appealed to CSC, which confirmed CSCRO-IV’s decision on March 20, 2002. Her subsequent motion for reconsideration was denied on August 20, 2002.
8. Maniebo then appealed to the Court of Appeals (CA) but failed to provide certified true copies of the required documents, leading to the dismissal of her petition on September 5, 2002.
9. Her motion for reconsideration on October 23, 2002, promised to submit the required documents within 10 days due to logistical issues. However, the CA dismissed the motion for being procedurally defective.
10. A second motion for reconsideration was filed but dismissed on June 5, 2003, as it was prohibited under Rule 52, Sec. 2, of the Rules of Court.
11. Maniebo then filed a petition for review on certiorari to the Supreme Court.
**Issues**:
1. Did the Court of Appeals commit reversible error in dismissing Maniebo’s petition for review because she failed to attach certified true copies of the necessary annexes?
2. Was the CA’s dismissal based on a technicality contrary to jurisprudence and due process?
**Court’s Decision**:
1. **Compliance with Procedural Rules**:
– The Supreme Court found no reversible error in the CA’s decision. Section 6, Rule 43 of the Rules of Court requires a petition for review to be accompanied by a certified true copy of the resolution appealed from and other supporting material portions of the record. This rule ensures that the CA has all the necessary documents to decide whether to proceed with the appeal.
– Maniebo’s failure to adhere to this procedural rule was not mitigated by her appeal to procedural leniency, given that the CA needed substantial compliance.
2. **Issues of Substantial Justice**:
– Despite Maniebo’s claim of financial difficulty and logistical challenges, she failed to submit the documents even during the extended period she had requested. Her subsequent actions, such as filing prohibited motions for reconsideration without addressing the procedural shortcomings, further justified the CA’s strict adherence to procedural rules.
3. **Allegation of Good Faith**:
– The Supreme Court found Maniebo’s defense of good faith untrustworthy. Her assertion of receiving the falsified rating by mail was weak and unsupported by evidence such as a certification from the relevant postmaster. Her possession of and reliance on the falsified rating suggested complicity.
4. **Claim of Eligibility Under Republic Act No. 6850**:
– Republic Act No. 6850, which grants eligibility to provisional or temporary employees who served efficiently for at least seven years, does not automatically convert a temporary status into a permanent one without CSC evaluation and a new appointment.
– Maniebo’s false representation of eligibility disqualified her from benefiting under RA 6850, which also requires compliance with ethical standards.
**Doctrine**:
– **Strict Compliance with Procedural Rules**: Rules of court require diligent adherence to ensure the adjudicative efficiency and reliability of judicial processes.
– **Burden of Proof in Claims of Good Faith**: When confronted with evidence to the contrary, claims of good faith must be substantiated by concrete evidence.
– **Application of Republic Act No. 6850**: Temporary service or subsequent eligibility attainment does not automatically convert to permanent appointment; compliance with ethical standards and CSC evaluation remain necessary prerequisites.
**Class Notes**:
– **Procedural Compliance**: Section 6, Rule 43, Rules of Court: Essential to attach certified copies of the judgment and material portions of the record to appeals.
– **Substantial Compliance Doctrine**: Even cited relaxations in procedural rules require substantial compliance, and lapses cannot be routinely excused.
– **Good Faith Evidence**: Must be substantiated against established records or contradicting evidence.
– **RA No. 6850**: Eligibility for provisional employees requires further CSC evaluation notwithstanding subsequent eligibility acquisition; ethical conduct remains crucial.
**Historical Background**:
– The case arose in the context of Civil Service reform efforts in the Philippines, emphasizing the integrity and merit system for government appointments. It reflects the judiciary’s vigilance against any form of dishonesty or misrepresentation within the civil service system, reinforcing the standards and procedures critical to upholding public trust in government offices.
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