Answer (Dishonesty)

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Republic of the Philippines

CIVIL SERVICE COMMISSION


Regional Office No. 8
Government Center, Palo, Leyte

TONGKO, ROMEO CSCRO8 Adm. Disciplinary


/Serious Dishonesty, Falsification of Case No. ________
Official Document, and Conduct
Prejudicial to the Best Interest of the
Service
x-------------------------------------------------------------------------------------------
-----x

ANSWER

RESPONDENT, represented by the undersigned counsel, in the


above-captioned case, unto this Honorable Regional Office of the
Commission, most respectfully alleges: THAT---

1. RESPONDENT admits Nos. 1, 2, 3 and 4 of the formal charge;


however, the foregoing facts and circumstances are not indicative or
constitutive of illegal acts of serious dishonesty, falsification of official
document and conduct prejudicial to the best interest of the service.

2. The Personal Data Sheets dated 27 May 2019 that he submitted in


support of his promotion is true and correct of his personal knowledge.

3. Respondent, in fact, enrolled and attended Central Visayas


Polytechnic College in Dumaguete City, Negros Oriental in SY 1998-99 to
2001-02, to earn units and finally graduate in Bachelor of Science in
Geology on March 2002, evidenced by the Official Transcript of Records
duly issued and signed by the incumbent officials of the school, hereto
attached as Annex “1” and made an integral part hereof.

4. That the incumbent officials of said school, namely: Dean Michael


Anderson and Registrar Purisima Margallo, have executed their respective
affidavits in support of this fact; as a matter of fact, in their affidavits, they
have affirmed and confirmed their signatures in the official transcript of
records and diplomas issued to the concerned geologist who indeed enrolled
in their school under a special cirruculum. In evidence, the affidavits of
Dean Michael Anderson and Registrar Purisima Margallo are hereto
attached as Annex “2” and “3” and made an integral part hereof.

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5. The only problem here is the fact that there has been a sudden
change of officials in the school, and there was no proper turn-over of the
records from the previous Registrar (Margallo) to the current Registrar
(Josefina Anjon), who wrote a letter dated 13 February 2006 that education
records of some geologists whose appointments were submitted to the CSC
could not be verified, as she did not find the names of these geologists, such
as the herein respondent.

6. But this circumstance should not make a factual or legal conclusion


that there was dishonesty or falsification of document.

7. The previous Registrar (Margallo) has stated under oath in her


affidavit, and repeatedly testified in the several hearings against fellow
geologists under the same predicament as me for having enrolled and
graduated in Central Visayas Polytechnic College, that school records of the
respondent-geologists may have been lost, as several incidents of ransacking
the office have been reported in the police blotter.

8. The hearings referred to is not exclusive of the Honorable Civil


Service Commission, but also in the administrative case filed by MGB RO8
against herein respondent and other fellow geologists in Adm. Case No. 01-
11-08 for Dishonesty (Submitting Fake/Fraudulent Scholastic Records).
However, in the quasi-judicial proceedings conducted by the MGB RO8, a
Decision has been rendered against herein respondent and fellow geologists
on 6 May 2008, exonerating them of the charge; a copy of the Decision is
hereto attached as Annex “4” and made an integral part hereof.

9. As it stands, the MGB RO8 assumed primary jurisdiction over the


case of Dishonesty against the same respondent/s, rendering a valid Decision
after due hearing. The set of facts and pieces of evidence are repeated,
repleaded and adoptable in the proceedings now before the Honorable Civil
Service Commission.

WHEREFORE, in view of the foregoing premises, it is respectfully


prayed of this Honorable Office of the Commission to dismiss the case for
lack of substantial evidence.
Respondent hereby states that he elects to have a formal investigation
in the above-captioned case.

Palo, Leyte. 17 January 2020.

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SADIE MINTARI RAQUE
Counsel for Respondent Romeo Tongko
Room #15, Raque Arcade, Candahug, Palo, Leyte
Roll No. 00000
IBP Lifetime No. 00000
PTR No. 0000000; 0-0-100 Tacloban City
MCLE Compliance No. III-0000000; 00-00-00

Republic of the Philippines )


Province of Leyte ) SS
Municipality of Palo )

VERIFICATION

I, ROMEO TONGKO, of legal age, married, Filipino, and a resident


of Jaro, Leyte, after being first sworn according to law, hereby depose and
state: that—

I am the respondent in the above-captioned case; that I caused the


foregoing ANSWER to be prepared and filed with the Commission; that I
have read all the allegations thereon contained, and that the same are all true
and correct to the best of my own personal knowledge and based on
authentic documents/records.

IN WITNESS WHEREOF, I have hereunto set my hand this 17


January 2020 at Palo, Leyte, Philippines.

ROMEO TONGKO
Respondent

SUBSCRIBED AND SWORN to before me in Palo, Leyte this 17


January 2020 by Romeo Tongko, personally known to me, who is the same
person who personally signed before me the foregoing Verification and
acknowledged that he executed the same.

Doc. No. ___


Page No. ___
Book No. ___
SERIES OF 2020

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COPY FURNISHED: by personal service

Atty. Mark Sumangguid, CESO III


Director IV, CSC R08, Palo, Leyte

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