- Petitioner
- Navarro
- Respondent
- Office of the Ombudsman
- Citation
- G.R. No. 210128
- Court
- Office of the Ombudsman to Court of Appeals (CA) to Supreme Court (SC)
- Division
- Second Division
- Ponente
- Mendoza, J.
- Decided
- August 17, 2016
Summary
The Supreme Court reversed the dismissal of BIR officer Atty. Amado Q. Navarro who was charged with administrative offenses for allegedly making false SALN declarations. The Ombudsman and Court of Appeals found him guilty of dishonesty, grave misconduct, and violation of RA 6713 for supposedly misdeclaring assets and acquiring properties disproportionate to his income. However, the Supreme Court found that Navarro's 'lumping' of properties in his SALN did not constitute dishonesty or misconduct absent proof of intent to deceive. The Court emphasized that under RA 6713, authorities must first inform employees of SALN deficiencies and allow corrective action before filing charges. Since Navarro provided adequate explanations with documentary evidence showing legitimate income sources and was never given opportunity to correct his SALN, his exoneration was warranted. The case establishes important precedent on SALN compliance procedures and the requirement of malicious intent for administrative liability.