Case Digest (G.R. No. 201176) Core Legal Reasoning Model
Facts:
The case revolves around Estrella Abid-Babano, who served as a Regional Director of the Department of Education in Region XII. The events leading to the case began with the Presidential Anti-Graft Commission (PAGC) formally charging her on March 20, 2007, based on an anonymous complaint. The allegations included her failure to declare certain motor vehicles and properties in her Statement of Assets, Liabilities and Net Worth (SALN) for the years 2000 to 2005. Specifically, she did not disclose two vehicles registered in her husband’s name, which was Macmod S. Pangandaman, a public servant required to file his own SALN. The complaint highlighted the inconsistency in declaring her properties, claiming she had only one lot while owning three. The PAGC recommended her suspension for six months and one day to one year, but found her not guilty of several charges, including dishonesty. The Office of the President (OP) affirmed PAGC's findings on October 19, 2007, but imposed a lighter... Case Digest (G.R. No. 201176) Expanded Legal Reasoning Model
Facts:
Background of the Case
Petitioner Estrella Abid-Babano, a Regional Director of the Department of Education-Region XII, was charged with violating Section 8 of Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees) and Section 46(b)(1) of Executive Order No. 292 (Administrative Code of 1987) for failing to declare in her Statement of Assets, Liabilities, and Net Worth (SALN) two motor vehicles registered under her husband’s name for the years 2000 to 2005.
Undisputed Facts
The Presidential Anti-Graft Commission (PAGC) found petitioner guilty of simple neglect of duty for failing to disclose the motor vehicles owned by her husband, Macmod S. Pangandaman, who was also a public servant required to file his own SALN. The PAGC recommended her suspension for six months and one day to one year. The Office of the President (OP) upheld the PAGC’s findings but reduced the penalty to six months of suspension.
Petitioner’s Defense
Petitioner argued that the undeclared motor vehicles were not hers but her husband’s. She also claimed that she correctly declared the value of the assets in her SALN, albeit inaccurately, due to inadvertence. She further contended that her marriage to her husband, a Muslim, was governed by a regime of complete separation of property under Presidential Decree No. 1083 (Code of Muslim Personal Laws), and thus, she was not required to disclose her husband’s properties.
Court of Appeals Decision
The Court of Appeals (CA) affirmed the OP’s decision, ruling that Republic Act No. 6713 requires the disclosure of a spouse’s assets without exception, regardless of the property regime governing the marriage.
Issues:
The sole issue before the Supreme Court was:
Whether the non-inclusion by petitioner in her SALN of the vehicles owned by and registered in the name of her husband constitutes neglect of duty or a mistake in good faith.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)