Case Summary (G.R. No. 176058)
Facts of the Case
On December 19, 2002, the PAGC received an anonymous complaint regarding Salvador A. Pleyto, accusing him of various misdeeds including extortion and manipulation of DPWH projects. Following this, Pleyto submitted his sworn Statements of Assets, Liabilities, and Net Worth (SALNs) for the years 1999, 2000, and 2001. The PAGC discovered that while Pleyto admitted his wife was a businesswoman, he failed to disclose her business interests in these SALNs. Consequently, on April 29, 2003, the PAGC filed charges against Pleyto for violating relevant sections of R.A. 6713 and R.A. 3019.
Arguments and Developments
Pleyto contended that there were no business interests to declare, which he indicated by writing "NONE" on his SALN. He also claimed that mistakes in the SALNs were due to the contributions of his wife's bookkeeper. Following an investigation, the PAGC found him guilty of the charges and recommended his dismissal with forfeiture of benefits. Pleyto's request for reconsideration argued against the charges on the basis of procedural grounds under the Review and Compliance Procedure established in R.A. 6713.
On March 11, 2005, the PAGC was directed by the Executive Secretary to reinvestigate the case. The reinvestigation revealed that Pleyto's wife held significant business interests, which were not disclosed in his SALNs. PAGC maintained its position, and the OP ultimately denied Pleyto's motion for reconsideration. Pleyto then sought relief from the Court of Appeals, which sided with him and enjoined the PAGC and OP from enforcing their decisions.
Issues Presented
The case presented two main issues:
- Whether the Court of Appeals erred in not finding Pleyto's failure to disclose his spouse's business interests in his SALNs as a violation of R.A. 6713.
- Whether the Court of Appeals was correct in determining that Pleyto should have been given the opportunity to correct his SALNs under the Review and Compliance Procedure before facing administrative charges.
Court's Rulings
This Supreme Court ruling was informed by prior cases where similar issues arose regarding public officials' SALNs. It reaffirmed that while Pleyto's failure to disclose his spouse's business interests constituted simple negligence, it did not rise to the level of gross misconduct or dishonesty warranting dismissal from service. The Court emphasized that negligence, defined as a lack of due diligence, was present as Pleyto failed to ensure the accuracy of his SALNs. However, the absence of fraudulent intent or deceitful motive in his actions led to a
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Case Overview
- This case deals with the administrative dismissal of Salvador A. Pleyto, a department undersecretary, for failing to accurately declare his wife’s business interests in his Sworn Statement of Assets, Liabilities, and Net Worth (SALN).
- The main legal issues revolve around the interpretation of Republic Act (R.A.) 6713 and R.A. 3019 concerning public officials' disclosure obligations.
Facts of the Case
- On December 19, 2002, the PAGC received an anonymous complaint alleging misconduct by Pleyto, including extortion and manipulation of projects at the Department of Public Works and Highways (DPWH).
- Pleyto submitted his 1999, 2000, and 2001 SALNs during the PAGC's investigation, noting his wife as a businesswoman but omitting her specific business interests.
- On April 29, 2003, the PAGC charged Pleyto with violations of R.A. 6713 and R.A. 3019 due to his incomplete SALNs.
- Pleyto contended that both he and his wife did not have business interests, thus indicating "NONE" in the relevant SALN sections.
- He attributed the inaccuracies in his SALNs to the preparation by his wife's bookkeeper.
Proceedings and Findings
- On July 10, 2003, the PAGC found Pleyto guilty, recommending his dismissal along with forfeiture of benefits.
- The Office of the President approved this recommendation on January 29, 2004.
- Pleyto filed a Motion for Reconsideration, arguing he should have been allowed to utilize the Review and Comp