San Diego v. Fact-Finding Investigation Committee

Summary

This administrative disciplinary case involved P/Insp. II Gilbert San Diego who was charged with multiple counts of grave misconduct and serious dishonesty for SALN violations and unauthorized foreign travel. The Supreme Court modified the lower courts' findings, reducing the charges from grave to simple offenses based on lack of malicious intent and substantial evidence. The Court found that while San Diego committed administrative violations, his actions constituted simple negligence rather than dishonesty or grave misconduct. The penalty was reduced from dismissal to 7 months suspension, with immediate reinstatement ordered. The decision emphasizes the distinction between simple and grave administrative offenses, requiring proof of malicious intent for the latter, and demonstrates the Court's careful review of administrative penalties to ensure proportionality.