RADINAL P. SANTOS, PETITIONER, V. CIVIL SERVICE COMMISSION, RESPONDENT.

Santos versus Civil Service Commission

The Case

This is the case of Santos versus Civil Service Commission, a petition for review brought by Radinal P. Santos against the Civil Service Commission. Santos was a Customer Service Assistant of the San Rafael Water District in Bulacan who was dismissed from the service for dishonesty, grave misconduct, and falsification of official documents after the Commission found that another person had taken the Career Service Professional Examination for and in his behalf. The case matters to every reviewee because it is the Supreme Court's cleanest statement of three connected rules: that findings of fact of administrative agencies are accorded great respect, even finality, when supported by substantial evidence; that public documents are admissible without further proof of genuineness; and that entries in official records are prima facie evidence of the facts stated therein, so that no examiner need be presented in court to identify them.

Procedural History

The case began as an administrative case before the Civil Service Commission Regional Office Number Three, docketed as Administrative Case Number D3-02-40, for dishonesty, grave misconduct, falsification of official documents, and conduct prejudicial to the best interest of the service. The Regional Office rendered a decision finding Santos guilty of serious dishonesty, grave misconduct, and falsification of official documents, and imposed dismissal from the service with the accessory penalties of cancellation of eligibility, forfeiture of retirement benefits, perpetual disqualification from reemployment in government service, and bar from taking any civil service examination. Santos moved for reconsideration, which the Regional Office denied for lack of merit.

Santos appealed to the Civil Service Commission, which treated the appeal as a petition for review. The Commission affirmed the Regional Office but modified the finding, holding Santos guilty only of plain dishonesty, grave misconduct, and falsification of official documents, while retaining the penalty of dismissal and all the accessory penalties. Santos moved for reconsideration, which the Commission denied. Santos then filed with the Supreme Court the petition for review under Rule 43 of the Rules of Court, assailing both Commission resolutions and praying that they be reversed and set aside.

Facts

On the first of March 2001, Radinal P. Santos was issued an appointment as Customer Service Assistant E at the San Rafael Water District in San Rafael, Bulacan. In support of that appointment he submitted a Personal Data Sheet, which he accomplished on the twenty-eighth of February 2001. In Item 19 of that sheet he stated that he had passed the Career Service Professional Examination, Computer Assisted Test, given on the sixth of December 2000 by the Civil Service Commission National Capital Region, with a rating of 85.14 percent. He also submitted a copy of a purported Certificate of Eligibility bearing Examination Number 115598WE, showing the same rating for the same examination.

Two letters, dated the twenty-second of March 2001 and the eighteenth of January 2002, arrived from persons identifying themselves as concerned citizens. Acting on these letters, the Regional Office investigated and noted discrepancies in the records of some examinees who took that same December 2000 examination at Room 002 of the Commission's National Capital Region Building. In particular, the picture and signature appearing on Santos's application form, filled in on the twenty-seventh of November 2000, and on the Picture Seat Plan of the examination, were different from the picture and signature on his Personal Data Sheet.

Santos was ordered to comment and to show cause. He filed a comment jointly with other water district employees, vehemently denying that another person took the examination for them. His explanation was found unsatisfactory, and a formal charge was issued against him. He filed an affidavit and an answer denying the charges for lack of sufficient and legal basis. A formal investigation followed. The Regional Office found him guilty, the Commission affirmed with modification, and the case reached the Supreme Court.

Issues

• Whether or not there is substantial evidence to hold the petitioner administratively liable for dishonesty, grave misconduct, and falsification of official documents.
• Whether or not the documentary evidence against the petitioner, consisting of public documents, may be relied upon without testimonial identification by the officials who conducted the examination.
• Whether or not the petitioner's testimonial evidence, including his witness's affidavit, sufficiently proves that he himself took the examination.

Applicable Provisions

The decision invokes the rule on entries in official records, which it discusses through the hearsay rule and its exceptions. The Court states the governing principle in these terms:

The law, however, provides for specific exceptions to the hearsay rule. One of the exceptions is the entries in official records made in the performance of duty by a public officer. In other words, official entries are admissible in evidence regardless of whether the officer or person who made them was presented and testified in court, since these entries are considered prima facie evidence of the facts stated therein.

This bears directly on the case because the application form and the Picture Seat Plan are official entries, and their contents may be used against Santos even without the testimony of the examiners who made them.

The decision also relies on the rule that public documents need no authentication, as pronounced in the cited jurisprudence:

The requirement of authentication of documentary evidence applies only to a private document. It is true that before a private document offered as authentic be received in evidence, its due execution and authenticity must first be proved. However, it must be remembered that this requirement of authentication only pertains to private documents and does not apply to public documents, these being admissible without further proof of their due execution or genuineness.

This answers Santos's objection that the evidence against him was purely hearsay, because the documents are public and are presumed genuine until the contrary is shown by clear and convincing proof.

Ruling

On the first issue, the Court held that there was substantial evidence to hold Santos liable. The documentary evidence showed that another person took the examination for and in his behalf. The picture attached to, and the signature affixed in, his Personal Data Sheet were starkly different from the picture and signature in his application form and in the Picture Seat Plan. The Court quoted the Commission's finding that the difference of the person appearing in the pictures and signatures on these documents will indubitably establish that a different person applied for and took the examination for and in behalf of Santos. The Court added that the act of misrepresenting in the Personal Data Sheet that he had civil service eligibility constituted dishonesty and falsification of official documents.

On the second issue, the Court held that the application form and the Picture Seat Plan could properly be relied upon even without the testimonies of the officials who conducted the examination. Being public documents, they were admissible without further proof of genuineness, and their entries were prima facie evidence of the facts stated. The Court also invoked the presumption of regularity in the performance of official duty, noting that strict procedures are followed during civil service examinations, so that examiners would not allow an examinee who did not look like the person in the submitted picture to take the examination.

On the third issue, the Court held that the affidavit of Santos's witness did not prove that Santos took the examination. The witness merely stated that he saw Santos going to the place of the examination and waited for him until he finished, which did not show that the witness saw Santos actually take the examination. The Court closed by restating the settled rule that, by reason of the special knowledge and expertise of administrative agencies over matters falling under their jurisdiction, their findings of fact are accorded not only great respect but even finality, especially when supported by substantial evidence.

Doctrine

A Bar candidate should retain three rules. First, findings of fact of administrative agencies, such as the Civil Service Commission and its regional offices, are accorded not only great respect but even finality when supported by substantial evidence. Second, public documents are admissible in evidence without further proof of their due execution or genuineness, and the requirement of authentication applies only to private documents. Third, entries in official records made in the performance of duty by a public officer are an exception to the hearsay rule; they are admissible regardless of whether the officer who made them is presented in court, because they are prima facie evidence of the facts stated therein, grounded on necessity and trustworthiness. These rules together mean that a discrepancy between the pictures and signatures in an examinee's Personal Data Sheet and those in the application form and Picture Seat Plan supports a finding that another person took the examination, and that such finding sustains a dismissal for dishonesty, grave misconduct, and falsification of official documents.

Disposition

The Supreme Court denied the petition for review, so the Civil Service Commission prevailed and Santos's dismissal from the service, with all its accessory penalties, stands.

Remember This

Memorize this line: public documents need no authentication, and entries in official records are prima facie evidence of the facts stated even without the testimony of their maker. Examiners use this case in evidence questions on the hearsay exception for official records and in administrative law questions on the finality accorded to findings of fact of the Civil Service Commission.