Professional Documents
Culture Documents
176058
ABAD, J.:
This case is about the dismissal of a department undersecretary
for failure to declare in his Sworn Statement of Assets,
Liabilities, and Net Worth (SALN) his wifes business interests
and financial connections.
Issues Presented
This case presents the following issues:
After threshing out the other issues, this Court found that
Pleytos failure to disclose his wifes business interests and
SEC. 4. Norms of Conduct of Public Officials and Employees. (A) Every public official and employee shall observe the
following as standards of personal conduct in the discharge and
execution of official duties:
(a) Commitment to public interest. - Public
officials and employees shall always uphold the
public interest over and above personal interest.
All government resources and powers of their
respective offices must be employed and used
efficiently, effectively, honestly and
economically, particularly to avoid wastage in
public funds and revenues.
(b) Professionalism. - Public officials and
employees shall perform and discharge their
duties with the highest degree of excellence,
professionalism, intelligence and skill. They
shall enter public service with utmost devotion
and dedication to duty. They shall endeavor to
discourage wrong perceptions of their roles as
dispensers or peddlers of undue patronage.
(c) Justness and sincerity. - Public officials and
employees shall remain true to the people at all
times. They must act with justness and sincerity
and shall not discriminate against anyone,
especially the poor and the underprivileged.
They shall at all times respect the rights of
others, and shall refrain from doing acts
contrary to law, good morals, good customs,
public policy, public order, public safety and
public interest. They shall not dispense or
This Court has too often declared that any act that falls short of
the exacting standards for public office shall not be
countenanced.31 The Constitution categorically declares as
follows:
SECTION 1. Public office is a public trust. Public officers and
employees must at all times be accountable to the people, serve
them with utmost responsibility, integrity, loyalty, and
efficiency, act with patriotism and justice, and lead modest
lives.32
Petitioner should have complied with her promise to return the
amount to respondent after failing to accomplish the task she
had willingly accepted. However, she waited until respondent
sued her for estafa, thus reinforcing the latters suspicion that
petitioner misappropriated her money. Although the element of
deceit was not proven in the criminal case respondent filed
against the petitioner, it is clear that by her actuations,
petitioner violated basic social and ethical norms in her private
dealings. Even if unrelated to her duties as a public officer,
petitioners transgression could erode the publics trust in
government employees, moreso because she holds a high
position in the service.
As to the penalty, we reprimanded the respondents in Joson
and imposed a fine in Jamsani-Rodriguez. Under the
circumstances of this case, a fine of P15,000 in lieu of the three
months suspension is proper. In imposing said fine, we have
considered as a mitigating circumstance petitioners 37 years of
public service and the fact that this is the first charge against
her.33 Section 5334 of the Revised Uniform Rules on
Administrative Cases in the Civil Service provides that
mitigating circumstances such as length of service shall be