G.R. No. 169982 ; November 23, 2007
SALVADOR A. PLEYTO, Petitioner, vs. PHILIPPINE NATIONAL POLICE CRIMINAL INVESTIGATION AND DETECTION GROUP (PNP-CIDG), Respondent.

FACTS

The PNP-CIDG filed a complaint with the Office of the Ombudsman against DPWH Undersecretary Salvador A. Pleyto and his family for alleged unexplained wealth, violation of laws on forfeiture of unlawfully acquired property, and perjury/falsification of public documents. The complaint was based on a joint affidavit alleging that Pleyto and his family accumulated numerous real properties in Bulacan and a renovated residence in Quezon City, took frequent foreign trips from 1993 to 2002, and that these assets and expenditures were grossly disproportionate to Pleyto’s income. It was also alleged that Pleyto failed to declare all these assets and their true value in his Statements of Assets and Liabilities and Net Worth (SALNs) for 2001 and 2002.
In his defense, Pleyto admitted ownership of the properties but claimed they were acquired through his wife’s separate lending business via foreclosure or dacion en pago. He asserted his family’s independent financial means, with his wife running several businesses for 25 years and his children being successful professionals. He also contended that many of the foreign trips were sponsored or paid for independently. The Ombudsman found Pleyto guilty of Grave Misconduct and Dishonesty and dismissed him from service, a decision affirmed by the Court of Appeals.

ISSUE

Whether the Office of the Ombudsman correctly found petitioner Salvador A. Pleyto guilty of Grave Misconduct and Dishonesty warranting dismissal from service.

RULING

Yes. The Supreme Court affirmed the findings of the Ombudsman and the Court of Appeals. The Court held that substantial evidence supported the administrative charges. Pleyto’s failure to accurately declare his and his wife’s real properties in his SALNs constituted dishonesty. The requirement to file a truthful SALN is a sacred duty for public officers, and any false narration therein, whether willful or negligent, violates the law and erodes public trust. The Court rejected Pleyto’s defense that the properties belonged to his wife’s separate business, noting that the SALN form explicitly requires the declaration of the spouse’s assets. His omission to disclose these, despite their acquisition being recorded in his wife’s name, demonstrated a lack of transparency.
Furthermore, the Court found the aggregate value of the family’s assets and foreign travels, when juxtaposed with Pleyto’s legitimate income as a public official, prima facie indicated wealth disproportionate to his salary. While not a criminal conviction for ill-gotten wealth, this disproportion, coupled with the proven dishonesty in his SALNs, constituted Grave Misconduct. Misconduct becomes grave when it involves elements of corruption, a clear intent to violate the law, or a flagrant disregard of established rules, all of which were present. The penalty of dismissal from service with its accessory penalties was therefore justified.