AM 2005 27 SC; (March, 2006) (Digest)
G.R. No. A.M. No. 2005-27-SC March 31, 2006
RE: DROPPING FROM THE ROLLS OF MS. CAROLYN C. ARCANGEL
FACTS
Ms. Carolyn C. Arcangel, a human resource management assistant in the Leave Division of the Office of the Court Administrator, was reported absent without official leave (AWOL) starting July 21, 2005. The Office of Administrative Services directed her to report back and explain her absence. In her September 2, 2005 explanation, she cited the need to care for a hospitalized aunt and her own subsequent illness due to exhaustion. Despite this, she failed to return to work or file a formal leave application.
Subsequently, it was discovered that Ms. Arcangel had custody of missing leave cards belonging to lower court personnel. She was formally directed on October 6, 2005, to explain the missing documents and to surrender them within forty-eight hours. She neither complied with this directive nor reported for duty, remaining on AWOL for over three months. Atty. Eden Candelaria of the OAS recommended she be dropped from the rolls.
ISSUE
Whether Ms. Carolyn C. Arcangel should be dropped from the rolls due to her prolonged absence without official leave and her failure to account for official documents in her custody.
RULING
Yes, the Supreme Court ordered Ms. Arcangel dropped from the rolls. The legal basis is Rule XVI, Section 63 of the Omnibus Civil Service Rules and Regulations, as amended, which mandates that an employee continuously absent without approved leave for at least thirty days shall be separated from service or dropped from the rolls. Ms. Arcangel’s absence from July 21, 2005, far exceeded this period without any approved leave, triggering the application of this rule.
The Court emphasized that such prolonged and unreasonable absence constitutes conduct prejudicial to public service, violating the public servant’s duty to serve with responsibility, integrity, loyalty, and efficiency. Her AWOL status forced colleagues to assume her duties, prejudicing the service. Furthermore, her failure to account for and return the missing official leave cards in her custody compounded her dereliction, demonstrating irresponsibility in handling court records. The conduct of judiciary personnel must uphold public accountability and maintain public faith in the institution. Therefore, dropping her from the rolls was warranted, and she was ordered to account for and return all missing documents within three days, under threat of criminal action.