Facts:

The case involves Remia F. Boncalon, a Cashier IV at the Bago City Treasurer's Office in Negros Occidental, who was administratively charged with dishonesty. The events leading to the case began on November 25, 1997, when Loida C. Arabelo, the State Auditor II, conducted an audit of Boncalon's cash accounts. The audit revealed a significant cash shortage of P1,023,829.56. Further investigation uncovered that Boncalon had falsely recorded a deposit of P1,019,535.21 in her cashbook dated October 31, 1997, when in fact, the actual deposits were made on November 25, 1997, and December 22, 1997, totaling P200,000.00 and P819,535.21, respectively. Following these findings, Boncalon was charged with dishonesty before the Office of the Ombudsman (Visayas), which was docketed as OMB-VIS-ADM-99-0488. Boncalon denied any wrongdoing, claiming she was only informed of the alleged shortage on October 1, 1998, after taking a leave of absence. She argued that the cash in question was...

Facts:

1. Audit and Cash Shortage:

• On November 25, 1997, Loida C. Arabelo, State Auditor II of Bago City, Negros Occidental, conducted an audit on the cash accounts of Remia F. Boncalon, Cashier IV at the Bago City Treasurer's Office.
• The audit revealed a cash shortage of P1,023,829.56.
• The state auditor discovered that the entry in Boncalon's cashbook for a deposit of P1,019,535.21 on October 31, 1997, was false. The actual deposits were made on November 25, 1997 (P200,000) and December 22, 1997 (P819,535.21).

2. Administrative Charge:

• Boncalon was administratively charged with dishonesty before the Office of the Ombudsman (Visayas) under OMB-VIS-ADM-99-0488.
• Boncalon denied accountability, claiming she was informed of the alleged shortage only on October 1, 1998, after she had gone on a commuted leave of absence from April 13, 1998, to July 15, 1998, during which she was cleared of money and property accountability.

3. Initial Recommendation and Reversal:

• Graft Investigation Officer (GIO) I Alvin Butch E. Cañares recommended the dismissal of the case, stating the questioned amounts were already accounted for and the false entry was an administrative lapse.
• Director Virginia Palanca-Santiago of the Office of the Ombudsman (Visayas) reversed the recommendation, ruling that the untimely deposit and falsification of the cashbook entry indicated dishonesty.

4. Court of Appeals Decision:

• The Court of Appeals upheld the Ombudsman's decision, finding Boncalon guilty of dishonesty under Section 23, Rule XIV of the Omnibus Rules on Civil Service.
• The court emphasized that entries in the cashbook are the direct responsibility of the cash accountable officer, and Boncalon's certification that she produced all cash items contradicted her claim of overlooking the bundles of money.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Dishonesty and Accountability:

   • The Court found that Boncalon's actions constituted dishonesty. The false entry in the cashbook, the untimely deposits, and her failure to account for the funds in her custody demonstrated a lack of integrity.
   • The Court rejected Boncalon's explanation that the false entry was an innocent mistake, noting that the amount involved was too large to be overlooked and that her certification contradicted her claim.

2. Due Process:

   • The Court held that Boncalon was not deprived of due process. She was given multiple opportunities to explain her side, including through letters and during investigations, and participated in all stages of the administrative proceedings.

3. Ombudsman's Authority:

   • The Court affirmed that the Ombudsman has the authority to impose administrative penalties, including dismissal, under Section 13(3) of Article XI of the 1987 Constitution and Section 15(3) of Republic Act No. 6770. The Ombudsman's power is not merely recommendatory but mandatory.

4. Public Trust and Accountability:

   • The Court reiterated that public office is a public trust, and public officers must serve with utmost responsibility, integrity, loyalty, and efficiency. Boncalon's actions violated these principles, warranting her dismissal.

Conclusion:

The Supreme Court upheld the penalty of dismissal, forfeiture of benefits, and perpetual disqualification from public office, emphasizing the importance of honesty and accountability in public service.