G.R. No. L-22733 - Benedicto vs. Court of Appeals

This is a Petition for Review on Certiorari (under Rule 45 of the Rules of Court, as amended) filed by the Office of the Ombudsman challenging the Court of Appeals’ decisions.
The petition assailed the CA Decision dated October 29, 2015, and the Resolution dated June 20, 2016, which reversed and set aside the Ombudsman’s earlier decision dismissing respondent Lilah Ymbong Rodas from service for Serious Dishonesty.

Respondent Lilah Ymbong Rodas held the position of Engineer II at MARINA’s Regional Office No. 7, with a gross annual salary of P173,400.00 at the onset of the controversy in 2003.
In August 2003, an anonymous letter accused her of having acquired assets disproportionate to her declared income, prompting the Ombudsman to order MARINA to submit copies of her Statements of Assets, Liabilities and Net Worth (SALNs) for the years 1999 to 2003.
The SALNs revealed variations in the declared assets—such as real properties, personal properties, and vehicles—with an unexplained increase in net worth from P4,680,000.00 in 2002 to P5,586,000.00 in 2003.

Respondent had erroneously indicated the fair market value of her real properties instead of their acquisition cost from 2001 to 2003.
There was a dramatic and unexplained increase in assets not supported by her salary or any declared additional business.

Based on these discrepancies, the Ombudsman found respondent guilty of Serious Dishonesty for her willful concealment/non-declaration of savings from her previous employment and imposed the penalty of dismissal from service with accessory penalties, including forfeiture of benefits and perpetual disqualification from public office.
Respondent admitted that errors were made in her SALNs but explained that the undisclosed funds were legitimately acquired from her 19-year prior employment in the private sector, retirement benefits, and inheritances.

The Ombudsman’s Decision (August 28, 2009) and subsequent Order (October 13, 2011) found respondent guilty of Serious Dishonesty.
Respondent filed a Petition for Review with the CA, arguing that her failure to declare her private-sector savings did not automatically constitute dishonesty and that a proper explanation accounted for the alleged discrepancies.
On October 29, 2015, the CA rendered a decision reversing the Ombudsman’s dismissal:

The CA found respondent guilty only of Simple Negligence, not Serious Dishonesty.
Accordingly, the penalty imposed was suspension from office without pay for one (1) year.

The Ombudsman’s motion for reconsideration was denied, and further complications arose when respondent’s death was later noted (August 30, 2016), although the penalty was deemed immediately executory.

Respondent’s employment history, including detailed information on her prior work with various private companies, was submitted to justify the source of her savings.
The records and explanations demonstrate that the accumulated savings—amounting to P906,000.00—had a legitimate source and were not a product of malafide intent.
Arguments were also made concerning the humanitarian implications for her heirs regarding survivorship benefits, given the gravity of the administrative proceedings and her subsequent passing.

Whether the Court of Appeals correctly ruled that respondent was guilty only of Simple Negligence instead of Serious Dishonesty.
Whether the omission in respondent’s SALNs, in light of her provided explanations and evidence of previous earnings, justifies a finding of Serious Dishonesty.
Whether the failure to declare the savings, without evidence of an ulterior motive or fraudulent intent, should be treated as simple carelessness rather than an act of malafide deception.