G.R. No. 33648, July 30, 1930
MIGUEL R. CORNEJO, Municipal President of Pasay, petitioner, vs. ELIGIO NAVAL, Provincial Governor of Rizal, et al., respondents.

FACTS

Miguel R. Cornejo, the Municipal President of Pasay, Rizal, was convicted by the Court of First Instance of Rizal for the crime of falsification of a private document and sentenced to imprisonment and a fine. He appealed the conviction to the Supreme Court. After his conviction in the trial court, the Provincial Governor of Rizal filed an administrative complaint against Cornejo for “corruption and improper conduct unbecoming a public officer,” suspended him pending investigation by the Provincial Board, and the Board later recommended his suspension pending the final determination of his appeal. The Secretary of the Interior approved the suspension. Cornejo challenged the jurisdiction of the Provincial Board to suspend him, arguing that the grounds for suspension under the Administrative Code did not cover his conviction for a crime unrelated to his official duties.

ISSUE

Whether a provincial governor and provincial board have the authority to suspend a municipal president who has been convicted of falsification of a private document, based on charges of “corruption” under Section 2188 of the Administrative Code.

RULING

No. The Supreme Court granted the writ and declared the suspension without effect. The Court held that the suspension was invalid because the grounds specified in Section 2188 of the Administrative Code”neglect of duty, oppression, corruption, or other form of maladministration in office”are limited to misconduct related to the officer’s official duties. Applying the rule of strict construction (since suspension statutes are penal in nature) and the principle of ejusdem generis, the term “corruption” refers only to “corruption in office.” The crime of falsification of a private document, as defined under the Penal Code, does not inherently involve taking advantage of one’s official position, unlike falsification of a public document. Therefore, Cornejo’s conviction did not constitute “corruption” affecting his official integrity, and the provincial authorities acted in excess of their jurisdiction. The Court emphasized that expanding the scope of the law is a legislative, not judicial, function.