G.R. No. 94070 - Santos vs. Macaraig

Rosalinda de Perio-Santos, career service officer (Chief of Mission II, Ambassador Extraordinary and Plenipotentiary), was appointed on July 24, 1986 by President Corazon C. Aquino as Permanent Representative of the Philippines to the UN and other International Organizations in Geneva.
On April 6, 1987, she sought paid leave to spend Easter holidays in New York with her family at no government expense.

Petitioner purchased two non-transferable, non-refundable discounted tickets (SFr. 1,597) for herself and her adopted daughter Pia.
Before departure, she was ordered to join the Philippine delegation to the UNCTAD G-77 Preparatory Conference in Havana (April 20–26, 1987), entitling her to SFr. 2,996 for economy round-trip fare (Geneva–New York–Havana–New York–Geneva).
She used the discounted tickets (Geneva–New York–Geneva) for the official portion of the trip and claimed reimbursement of SFr. 1,597, saving the government SFr. 1,399.

On September 16, 1987, DFA queried why the infant Pia’s fare was included; petitioner replied her personal funds paid Pia’s share.
DFA discovered the ticket cost SFr. 950 for adult and SFr. 647 for child; it demanded refund of SFr. 647. Petitioner returned the full SFr. 1,597 instead of only SFr. 647.
She then claimed the full entitled amount of SFr. 2,996 for an economy round-trip ticket.

October 5, 1987: Charges filed against petitioner for incompetence, inefficiency, dishonesty, misconduct, and irregular transactions; initial investigation by Ambassador Ascalon.
November 26, 1987: Amb. Ascalon’s findings led to an Ad Hoc Committee, which found a prima facie case of dishonesty and other charges. Tanodbayan dismissed separate estafa charge for insufficiency of evidence.
March–April 1988: BFSA’s 5-man committee, en banc, recommended guilt for misconduct only, penalty of reprimand, and recall to the home office. Secretary Manglapus affirmed on April 27, 1988.

Petitioner moved for reconsideration, alleging no charge of misconduct had been filed; she refused further hearings. Secretary Manglapus on August 18, 1988 made the reprimand and recall final.
Appeal to Office of the President docketed as O.P. Case No. 3903; President nominated Narcisa L. Escaler as her successor (confirmed March 15, 1989).
March 30, 1989: Administrative Order No. 122 found petitioner guilty of dishonesty (based on her reimbursement certification and telex), imposed reprimand and recall.
January 9, 1990: Executive Secretary denied motion for reconsideration. Petitioner filed certiorari in the Supreme Court.

Whether petitioner’s use and reimbursement of discounted tickets, and failure to disclose inclusion of her daughter’s fare, constituted dishonesty under administrative law.
Whether the penalty of reprimand for dishonesty was supported by substantial evidence and free from grave abuse of discretion.
Whether the recall of petitioner to the home office was valid under applicable laws on foreign service assignments.
Whether petitioner’s tour of duty exceeded the permissible period, entitling her to remain in Geneva for four years.