- Petitioner
- Estrella M. Domingo
- Respondent
- Civil Service Commission
- Citation
- G.R. No. 236050
- Court
- National Archives of the Philippines (NAP) to Civil Service Commission (CSC) to Court of Appeals (CA) to Supreme Court (SC)
- Division
- First Division
- Ponente
- Lazaro-Javier, J.
- Decided
- June 17, 2020
Summary
Chief Archivist Estrella Domingo was charged with grave misconduct, serious dishonesty, and conduct prejudicial to service for attending a records management seminar without office approval. After Bacoor City's initial request was delayed, the Mayor personally invited Domingo, who attended during her approved leave as resource speaker. NAP and CSC found her guilty and ordered dismissal. The Court of Appeals affirmed. The Supreme Court reversed, finding no violation since Domingo attended during personal leave, not official time. No law required office approval for personal activities during leave. NAP materials were freely disseminable under IP Code. No misrepresentation or intent to defraud was proven. The Court emphasized that absent specific prohibitions, employees cannot be administratively punished for attending educational seminars during approved personal leave, especially when benefiting other government units.