G.R. No. 169982 - Pleyto vs. Philippine National Police Criminal Investigation and Detection Group

Petition filed by Salvador A. Pleyto challenging his dismissal from service after being found guilty of grave misconduct and dishonesty by the Office of the Ombudsman.
The administrative case stemmed from a complaint filed by the Philippine National Police – Criminal Investigation and Detection Group (PNP-CIDG) alleging violations of anti-graft laws, including RA 1379, RA 3019, and relevant provisions of RA 6713.
The complaint charged Pleyto and members of his family with amassing unexplained wealth through numerous real properties and frequent foreign trips that far exceeded his known lawful income.

A team composed of PNP-CIDG personnel and cooperating officers from other government agencies conducted an investigation.
Joint affidavits and documentary evidence (e.g., Transfer Certificates of Title, tax declarations, travel records) were gathered, indicating that:

Pleyto and his family acquired numerous properties in Bulacan and Quezon City.
There were discrepancies between the declared assets in his Statements of Assets and Liabilities (SALNs) and the actual properties owned.
The properties and foreign travel expenses appeared grossly disproportionate to his government salary.

Based on this evidence, the Office of the Ombudsman issued a preventive suspension order and later issued a decision dismissing Pleyto for grave misconduct and dishonesty.

Pleyto, then a DPWH Undersecretary, along with his wife and children, filed counter-affidavits and supplemental evidence explaining:

The properties were acquired through legitimate means such as foreclosure, purchase by installment, dacion en pago, or inheritance consistent with his wife’s long-standing business ventures (lending, piggery, pawnshop).
The alleged disparities in SALN entries were due to reliance on a family bookkeeper and administrative errors rather than deliberate concealment.
The foreign trips largely were sponsored or conducted at costs significantly lower than the arbitrary estimate of ₱100,000 per travel used by the investigating officers.

Pleyto contested that the net-worth-to-income discrepancy analysis should be based on the actual acquisition cost of properties rather than their current market value.

Pleyto sought relief before the Court of Appeals via a petition for review under Rule 43, including a prayer for a temporary restraining order to stop the enforcement of his dismissal.
The Court of Appeals initially granted a writ of preliminary injunction but eventually rendered a decision affirming his dismissal on the basis of discrepancies in his SALNs and unexplained wealth.
A key procedural issue arose when the Office of the Ombudsman, not named as a respondent in the appeal, actively intervened by filing comments and memoranda in the appellate proceedings.

The case involved an intensive review of whether the evidence established that Pleyto’s accumulation of properties and expenditures (e.g., foreign travel) were truly beyond his lawful financial capacity.
Detailed tables were introduced comparing his annual income with the declared net worth and acquisition costs, with the Ombudsman’s analysis hinging on the gross market value rather than acquisition cost.
The dispute over the evidentiary value of the declarations, supporting documents, and the evidentiary burden in proving intent to conceal assets was central to the administrative finding.

The improper intervention of the Office of the Ombudsman in the appellate case.
The insufficiency of evidence to substantiate a finding of gross misconduct and dishonesty.
Procedural issues regarding the opportunity to correct his SALN under the review and compliance procedure in Section 10 of the Code of Conduct.

The case reached the Supreme Court via a Petition for Review on Certiorari, challenging the decisions of both the Office of the Ombudsman and the Court of Appeals.

Whether the intervention of the Office of the Ombudsman in the appellate proceedings was proper given that it was not a party to Pleyto’s petition and should have remained detached.
Whether the evidence on record, including discrepancies in the SALNs and the net-worth-to-income discrepancy analysis, sufficiently supported a finding of gross misconduct and dishonesty or merely demonstrated negligence.
Whether the method of financial evaluation (comparing market value versus acquisition cost) was reliable in establishing that Pleyto’s wealth was unlawfully acquired.
Whether Pleyto should have been afforded an opportunity, under Section 10 of the Code of Conduct and Ethical Standards for Public Officials and Employees, to correct his SALN without incurring the harsh penalty of dismissal from service.