Dishonesty in Public Service: Perpetual Disqualification Despite Prior Offense

The Supreme Court has reminded all public servants, especially those in the Judiciary, that dishonest acts will follow them into their public careers. In Office of the Court Administrator v. Sarah P. Ampong, the Court enforced the dismissal of a court interpreter who, years before joining the Judiciary, impersonated another person in a civil service examination. The case clarifies that the timing of the offense does not erase administrative liability, and a final dismissal carries permanent consequences.

The Facts: A 1991 Impersonation Case Resurfaces

In November 1991, Sarah P. Ampong impersonated one Evelyn B. Junio-Decir in the Civil Service Eligibility Examination for Teachers, also known as the PBET. At the time, Ampong was a public school teacher. She later entered the Judiciary and became a Court Interpreter III at the Regional Trial Court of Alabel, Sarangani Province, Branch 38, starting August 3, 1993.

In August 1994, the Civil Service Commission (CSC) filed an administrative case against Ampong for dishonesty, grave misconduct, and conduct prejudicial to the best interest of the service. Ampong admitted the charges. On March 21, 1996, the CSC dismissed her from service, revoked her PBET rating, and imposed the accessory penalties of dismissal.

Ampong moved for reconsideration, arguing that the CSC no longer had jurisdiction because she had already been appointed to the Judiciary. Her motion was denied, and the Court of Appeals affirmed her dismissal. On August 26, 2008, the Supreme Court En Banc, in Ampong v. CSC (G.R. No. 167916), also denied her petition and affirmed the dismissal.

Despite that 2008 Decision, no official directive reached the Office of the Court Administrator (OCA), so Ampong continued receiving her salary and allowances. It was only when Executive Judge Jaime L. Infante wrote to the OCA in 2011 that the situation came to light. The OCA then initiated the present administrative matter to enforce the dismissal.

The Issue: Was Ampong Effectively Dismissed?

The sole issue was whether Ampong had already been dismissed from her position as Court Interpreter III. The Supreme Court answered in the affirmative.

The Ruling: Dismissal Is Final, and Penalties Must Be Enforced

The Court ruled that its August 26, 2008 Decision had already found Ampong guilty of dishonesty. That decision had become final, and under the doctrine of immutability of judgment, it could no longer be modified or reversed. Ampong's plea to revisit