G.R. No. 225774 - Jessie Javier Carlos vs. Department of Fice - Revenue Integrity Protection Service and Office of the Ombudsman

Jessie Javier Carlos was contracted as a Tax Specialist II at the Department of Finance - One-Stop Shop Tax Credit and Duty Drawback Center starting September 1, 2000, with an annual gross salary of ₱152,004.00.
His contract was renewed biannually until he was permanently appointed as Tax Specialist I on September 27, 2005.
On November 25, 2011, his annual gross salary was increased from ₱126,420.00 to ₱210,480.00.

Investigation by the Department of Finance - Revenue Integrity Protection Service (DOF-RIPS)

In 2012, DOF-RIPS investigated Carlos’ assets and lifestyle compared to his Statements of Assets, Liabilities, and Net Worth (SALNs) submitted from 2000 to 2010.
DOF-RIPS filed a Complaint before the Office of the Ombudsman against Carlos for failing to disclose in his SALNs:

A house and lot in Tondo, Manila worth ₱1,100,000.00 (loan-financed) for the years 2003-2008.
A Toyota Innova worth ₱973,000.00 (loan-financed) for the years 2007-2008.
His wife's business interest in Armset Trading in 2010, which was not disclosed because it was allegedly not operational.

Carlos was also accused of having assets disproportionate to his income including:

Carlos contended that his SALNs were filed in good faith.
He claimed he should have been given an opportunity to correct alleged omissions or mistakes pursuant to Section 10 of Republic Act No. 6713 (the Code of Conduct and Ethical Standards for Public Officials and Employees).
Regarding the Toyota Innova, he started paying installments in 2003 and fully paid in 2007, and removed it from his SALN when sold in 2010.
His wife’s business was not disclosed because it was non-operational at the time.
Carlos maintained he complied with disclosure requirements under RA 6713 and RA 3019 and argued the omissions were unrelated to his duties.

The Office of the Ombudsman found Carlos guilty of grave misconduct and gross neglect of duty and ordered his dismissal with accessory penalties.
The Court of Appeals reversed the Ombudsman, ruling:

The review and compliance procedure under Section 10 of RA 6713 does not apply when the Ombudsman investigates.
Carlos was guilty of dishonesty, not grave misconduct or neglect.
The penalty of dismissal with ancillary penalties was upheld.

Carlos filed a Petition for Review on Certiorari challenging denial of motions for reconsideration and the Court of Appeals’ ruling.
He argued deprivation of due process and lack of opportunity to correct SALNs under Section 10 of RA 6713.
The central issue is whether liability can be imposed without complying with the mandatory review and compliance procedure under Section 10 of RA 6713.

Whether the review and compliance procedure mandated by Section 10 of Republic Act No. 6713 is mandatory and a precondition to imposing administrative liability for errors, omissions, or non-submission of SALNs.
Whether the Office of the Ombudsman can impose administrative penalties for errors or omissions in SALNs without the government complying with the review and compliance procedure.
Whether petitioner Jessie Javier Carlos is guilty of dishonesty or grave misconduct based on the alleged SALN omissions without being afforded the opportunity to correct them.
The applicability and precedence of RA 6713 over other laws (RA 6770 and RA 3019) regarding the filing and prosecution of SALN violations.