ANONYMOUS, COMPLAINANT, VS. REVELYN O. ESTRERA, CLERK III, BRANCH 22, REGIONAL TRIAL COURT, KABACAN, NORTH COTABATO, RESPONDENT.

Anonymous versus Estrera

The Case

This is an administrative matter against Revelyn O. Estrera, Clerk III of Branch 22 of the Regional Trial Court of Kabacan, North Cotabato, arising from an undated anonymous letter to the Judicial Integrity Board accusing her of serious dishonesty relative to her civil service eligibility — specifically, that she faked her eligibility by having another person take the civil service examination in her name. The case matters because it is the Court's latest word on impersonation in civil service examinations: how it is proven, largely by comparing the photograph on the picture seat plan with the photograph on the employee's personal data sheet, and how it is punished under the new 2025 Code of Conduct and Accountability for Court Officials and Personnel, which took effect during the pendency of the case and superseded Rule 140 of the Rules of Court.

Procedural History

The anonymous letter was referred to the Office of the General Counsel because of its anonymous nature. The Office of the General Counsel secured Estrera's service record, verified her certificate of eligibility with the Civil Service Commission Regional Office No. XI, and, after noting discrepancies between the photograph on the picture seat plan and the photographs on her personal data sheet and unified multi-purpose identification card, formally charged her with serious dishonesty. The Judicial Integrity Board required a verified comment, which Estrera filed, praying for dismissal of the charges. The Acting Executive Director of the Judicial Integrity Board recommended a finding of guilt, and in an amended report recommended dismissal from the service with cancellation of civil service eligibility, forfeiture of benefits except accrued leave credits, and disqualification from reemployment in the government. The Judicial Integrity Board adopted the amended report and recommendation in a resolution dated September 18, 2025. The matter was then re-docketed as a regular administrative matter and resolved by the Supreme Court en banc, through this per curiam decision.

Facts

Estrera submitted a certificate of eligibility stating that she passed the Career Service Professional Examination held at the Civil Service Commission Regional Office No. XI on May 21, 1997, with a general rating of 87.30 percent, the certificate having been issued on the same date. When the Office of the General Counsel asked the Civil Service Commission Regional Office No. XI to verify the certificate, that office confirmed the certificate was authentic but requested a clear copy of Estrera's photograph to verify her identity. The Office of the General Counsel sent the photograph from her personal data sheet found in her 201 file.

In a letter dated August 23, 2022, the Civil Service Commission Regional Office No. XI noted significant discrepancies between the facial features in the photograph on the picture seat plan for the May 1997 examinations and the photograph on Estrera's personal data sheet, which likewise differed from her photograph on her unified multi-purpose identification card. The face shape, nose, eyebrows, ears, and lips did not match. It recommended further investigation. The Office of the General Counsel also observed discernible differences between Estrera's handwriting and signature on her personal data sheet and the handwriting and signature on the picture seat plan, the latter being more compact while hers appeared as scribbles with loops. It formally charged her with serious dishonesty.

In her defense, Estrera insisted she personally took the examinations in 1997 and attached older photographs, including a Comelec identification card, a photograph from her employment with a multipurpose cooperative, and a graduation picture. To counter the handwriting allegation, she attached a special power of attorney, a deed of mortgage, a promissory note, a performance appraisal rating, and a barangay clearance, and offered to submit the documents to a handwriting expert. She stressed that she had served the Judiciary with honesty for more than twenty years.

Issues

• Whether or not the respondent can be held administratively liable for serious dishonesty for having another person take the civil service examination on her behalf.
• Whether or not the respondent may additionally be held liable for falsification of a public document.
• Whether or not dismissal from the service is the proper penalty under the attendant circumstances.

Applicable Provisions

Section 3 of the Civil Service Rules classifies dishonesty as serious when qualified by certain circumstances, and provides:

The dishonest act involves a Civil Service examination, irregularity or fake Civil Service eligibility such as, but not limited to, impersonation, cheating and use of crib sheets.

This is the provision that raises Estrera's act from simple to serious dishonesty, because her offense is precisely impersonation in a civil service examination.

Section 19(e) of the 2025 Code of Conduct and Accountability for Court Officials and Personnel classifies serious dishonesty as a serious offense, and the Court applies it because the Code took effect during the pendency of the case and superseded Rule 140.

Section 22 of the same Code fixes the penalties for a serious offense, and provides:

If the respondent is found guilty of a Serious Offense, any of the following penalties shall be imposed: (a) Dismissal from service, forfeiture of all or part of the benefits as the Supreme Court may determine, and disqualification from reinstatement or appointment to any public office, including government-owned or -controlled corporations. Provided, however, that the forfeiture of benefits shall in no case include accrued leave credits; (b) Suspension from office without salary and other benefits for one year and one day up to two years; and/or (c) A fine of more than PHP 101,000.00 but not more than PHP 500,000.00.

This is the source of the penalty imposed, including the express reservation of accrued leave credits.

Ruling

On the first issue, the Court ruled in the affirmative and adopted the findings and recommendation of the Judicial Integrity Board. Jurisprudence defines dishonesty as intentionally making a false statement in a material fact, or practicing or attempting to practice any deception or fraud in securing examination, registration, appointment, or promotion. It is a question of intention, a willful and voluntary act that cannot be justified under the guise of negligence or ignorance. The Court held that impersonation, allowing one person to take the civil service examination on behalf of another to ensure a passing mark, is a form of dishonesty, and that the photograph on the picture seat plan bears no semblance to Estrera's facial features in her personal data sheet and unified multi-purpose identification card — a discrepancy even an ordinary person could discern. Her older photographs failed to overturn the consistent findings of the Civil Service Commission Regional Office No. XI, the Office of the General Counsel, and the Judicial Integrity Board. The Court relied on the presumption that Civil Service Commission officials regularly performed their duties in matching pictures and signatures to examinees, and on the picture seat plan being a public document whose entries are prima facie evidence of the facts stated. Following its earlier rulings, the Court held that no handwriting expert was needed, since even on mere ocular inspection the signatures could not have been executed by one and the same person.

On the second issue, the Court found insufficient evidence for falsification. The personal data sheet is a public document required of government employees, but Estrera's copy did not state that she was civil service eligible, so she committed no misrepresentation that could support that charge.

On the third issue, the Court held dismissal to be the proper penalty. Court personnel are sentinels of justice, and impersonation would not have been possible without the active participation of both the respondent and the person who took the examination in her name; she derived benefit from the passing result, and her misrepresentation enabled her to secure a permanent appointment as Clerk III. Having falsely obtained eligibility, she prejudiced other applicants who were truly qualified, and she is unfit to continue serving in the Judiciary.

Doctrine

Impersonation — allowing another person to take the civil service examination in one's name — is dishonesty, and it is serious dishonesty because the dishonest act involves a civil service examination, irregularity, or fake civil service eligibility under Section 3 of the Civil Service Rules. Dishonesty is a question of intention; it is a willful and voluntary act that cannot be excused as negligence or ignorance. It may be established by comparing the photograph and signature on the picture seat plan with those on the employee's personal data sheet, aided by the presumption that Civil Service Commission officials regularly performed their duties and by the picture seat plan being a public document whose entries are prima facie evidence. No handwriting expert is required; the Court may make its own ocular determination. Serious dishonesty is a serious offense under Section 19(e) of the 2025 Code of Conduct and Accountability for Court Officials and Personnel, punishable under Section 22 by dismissal, forfeiture of benefits except accrued leave credits, and disqualification from reemployment in the government.

Disposition

The Court found Revelyn O. Estrera guilty of serious dishonesty, dismissed her from the service effective immediately, cancelled her civil service eligibility, forfeited her retirement benefits except accrued leave credits, and perpetually disqualified her from reemployment in any government agency or instrumentality, including government-owned or controlled corporations.

Remember This

Memorize this line: impersonation in a civil service examination is serious dishonesty, provable by comparing the picture seat plan with the personal data sheet, and punishable by dismissal with cancellation of eligibility and perpetual disqualification. Examiners use this case to test the definition and proof of dishonesty, the presumption of regularity in Civil Service Commission records, and the application of the 2025 Code of Conduct and Accountability for Court Officials and Personnel.