De Castro vs. Field Investigation Office, Office of the Ombudsman

A public officer may be dismissed for Dishonesty when substantial evidence shows assets manifestly disproportionate to lawful income and deliberate concealment of those assets in the names of children who lacked capacity to acquire them; but the same acts do not constitute Grave Misconduct absent a direct nexus to the officer’s official duties.

Leovigildo A. De Castro was a career official of the Bureau of Customs, and his wife Marina Rios also served in government. The case concerns the SALN requirement for public officers and the Ombudsman’s mandate to investigate unexplained wealth under R.A. 3019 and R.A. 6713. The SALN requirement is governed by R.A. 3019 and R.A. 6713, while the Ombudsman is constitutionally empowered to investigate and prosecute erring public officials.

Leovigildo began working in the Bureau of Customs on December 4, 1973 as storekeeper at the Manila International Airport. Since then, he was assigned as Common Bonded Inspector in 1979, Common Bonded Supervisor in 1980, Customs Operations Assistant Chief in 1986, Supervising Customs Operations Officer in 1989, and Chief Customs Operations Officer in 1996. Marina Rios, his wife, began working as a clerk in the now defunct Philippine Atomic Energy Commission in July 1969, rose through the ranks, and retired as a training officer sometime in 1988. Based on the Certificates of Employment and Compensation, Leovigildo and Marina’s declared income from 1974 to 2004 amounted to ₱10,841,412.28.

Sometime in 2003, the Ombudsman, through its Field Investigation Office, conducted motu proprio lifestyle checks on government officials and employees, and Leovigildo was among those evaluated. The FIO found that Leovigildo’s annual salary as of 2004 was estimated at ₱303,052.54, including allowances and bonuses; that his SALNs from 1994 to 2003 showed neither he nor his spouse had financial connections and business interests, leaving him no other source of income except his salary; that in his SALNs from 1997 to 2003 he declared a residential house and lot in Parañaque, a house and lot in Taal, Batangas, and an agricultural land in Laguna, and disclosed a car worth ₱625,000.00 acquired in 2002; and that there were other properties and business interests not declared in his SALNs, such as his investment amounting to ₱416,669.00 in Lemar Export and Import Corporation, which was incorporated on May 25, 1994. The FIO also treated properties registered in the names of Leovigildo’s children as part of his undisclosed assets because, at the time of acquisition, the children had no sources of income or means of livelihood. These Disputed Assets were: (a) investment in Lemar Export and Import Corporation worth ₱625,003.50 acquired on May 25, 1994 by Marina Rose and Leo Gerald, jointly with Leovigildo, when Marina Rose was 18 and Leo Gerald was 24; (b) a 450-square-meter residential house and lot in Muntinlupa City worth ₱5,708,600.00 acquired on December 3, 1997 by Leo Gerald, then 27; (c) investment in De Castro Oral Implant Center worth ₱500,000.00 acquired on February 28, 1998 by Leo Gerald, then 28; (d) a condominium unit in Makati City worth ₱3,984,929.75 acquired on August 28, 1998 by Leo Gerald, then 28; (e) investment in Lemar General Trading worth ₱3,500,000.00 acquired on February 2, 1999 by Leo Gerald, Marie Aleli, Marie Antoinette, Leovigildo, Jr., and Marina Rose, then aged 29, 28, 26, 24, and 23, respectively; (f) a condominium unit in Ayala Alabang, Muntinlupa City worth ₱5,676,861.64 acquired on July 8, 1999 by Leovigildo, Jr., then 24; (g) a Toyota Land Cruiser worth ₱2,800,000.00 acquired on June 19, 2000 by Leo Gerald, then 30; (h) investment in Ceraco Corporation worth ₱120,000.00 acquired on December 19, 2001 by Leovigildo, Jr., then 26; (i) investment in Le Mar Dental Clinic worth ₱100,000.00 acquired on January 21, 2003 by Marina Rose, then 27; and (j) a Honda CRV Wagon worth ₱701,832.00 acquired on installment basis on February 27, 2004 by Marina Rose, then 28. The total value of the Disputed Assets was ₱23,717,226.89. The FIO further found, based on Bureau of Immigration records, that Leovigildo and his family had taken seventy outbound flights between 1993 and 2004 to several countries, including Japan, Hong Kong, and South Korea, and pegged the cost of such trips at ₱30,000.00 each, for a total estimated travel cost of ₱2,100,000.00. The FIO concluded that Leovigildo and Marina’s assets and expenses from 1974 to 2004 amounted to ₱30,829,603.48, which was manifestly disproportionate to their declared income of ₱10,841,412.28.

Consequently, the FIO filed a Complaint dated October 5, 2005 before the Ombudsman, charging Leovigildo with Dishonesty, Grave Misconduct and Conduct Prejudicial to the Best Interest of the Service pursuant to Section 22 of the Omnibus Rules Implementing Book V of Executive Order No. 292. In the same Complaint, the FIO prayed that a preliminary investigation be conducted against Leovigildo for violation of Section 8 of R.A. 6713 and Article 183 of the Revised Penal Code, and that forfeiture proceedings be lodged against Leovigildo, Marina, and their children. On March 24, 2006, the Ombudsman issued an Order placing Leovigildo under preventive suspension. In his Counter-Affidavit dated August 28, 2006, Leovigildo maintained that the assets which he and Marina acquired while in government service were all reported in their respective SALNs. He summarized these assets and averred that the net value of the assets he and Marina acquired for the period in question amounted only to ₱1,576,536.59. He argued that the FIO bloated his net worth by using the market values of the properties declared in his SALNs as basis for computation instead of their respective acquisition costs. He also insisted that his children were all professionals who possessed the financial capacity to acquire the Disputed Assets that the FIO wrongfully attributed to him, and he detailed their professional qualifications and sources of income. Finally, he denied the FIO’s claims regarding his family’s foreign trips, emphasizing that the documents which served as basis for these claims were not attached to the Complaint.

On March 26, 2007, the Ombudsman issued a Decision finding Leovigildo guilty of Dishonesty and Grave Misconduct and imposing dismissal from service, with cancellation of eligibility, forfeiture of retirement benefits, and perpetual disqualification for re-employment in the government service. The Ombudsman observed that while Leovigildo admitted that he and his wife acquired a house and lot in Taal, Batangas through inheritance in 1969, and subsequently purchased a 197.6-square-meter contiguous lot and built a house thereon in 1973 and 1988, respectively, these assets were not reported in his 1994, 1995, and 1996 SALNs. Leovigildo also failed to report that his wife won ₱2,000,000.00 from the sweepstakes in 1994. The Ombudsman found that while Leovigildo’s children were all practicing professionals at the time of the investigation, the documentary evidence on record showed that the cost of the Disputed Assets was grossly disproportionate to their respective incomes at the time of acquisition. The Ombudsman concluded that Leovigildo deliberately placed the Disputed Assets in the names of his children to exclude them from his SALNs, and that such deliberate exclusion, coupled with the fact that the acquisition cost of the Disputed Assets was manifestly out of proportion to Leovigildo and Marina’s declared income, gave rise to the prima facie presumption that these assets were unlawfully acquired. Leovigildo filed a Motion for Reconsideration dated May 2, 2007, which the Ombudsman denied on June 25, 2007 for lack of merit.

On appeal, the CA affirmed the Ombudsman. The CA held that the Ombudsman possessed ample authority to review Leovigildo’s SALN pursuant to its Constitutional mandate. On Leovigildo’s claim that the omissions in his 1994, 1995, and 1996 SALNs were not impelled by malicious intent, the CA stressed that Leovigildo’s liability rested not only on the omissions but primarily on his failure to explain the manifest disproportion between his declared income and the assets in his name and in the names of his children. The CA found that the Ombudsman’s findings were supported by “more than [a] substantial amount” of evidence. It noted that Leo Gerald, the eldest son, was the registered owner of a Makati condominium unit acquired in 1995 through installment and fully paid in 1998 in the total amount of ₱3,984,929.75; that the terms of payment purportedly undertaken by Leo Gerald were ₱100,000.00 on September 1, 1994, ₱447,323.96 per month for three months from October to December 1994 or a total of ₱1,341,971.90, ₱90,123.24 per month for 24 months from January 1995 to November 1996 or a total of ₱2,542,957.85, and a last payment on December 2, 1996 in the amount of ₱470,123.33; and that it was only on January 3, 1994 that Leo Gerald was issued his license to practice dentistry, making it highly incredible that he could have afforded those payments. The CA also noted that in 1994 Leo Gerald made an investment with Lemar Export and Import Corporation worth ₱208,334.50; that a year after the last installment for the condominium, he purchased a 450-square-meter property in Muntinlupa for ₱3,825,000.00 and built a house thereon valued at ₱1,883,600.00; that the supposed loan from his soon-to-be parents-in-law was undertaken on December 18, 1997, or 15 days after the full payment of the property on December 3, 1997; and that the Toyota Land Cruiser was acquired in cash in 2000 when Leo Gerald and his wife’s registered total annual net income was only ₱216,825.50. As to Leovigildo, Jr., the CA noted that he purchased a condominium unit at Richville Corporate Tower in Ayala, Alabang for ₱5,676,861.64 on January 14, 1999 when he was only 24 years old and still a law student, and that the alleged trust in favor of his first cousin was not supported by a declaration of trust filed with the Office of the Clerk of Court of Makati City as required by the Notarial Law. The CA also found that Marie Antoinette and her husband had a total income of ₱374,083.50 in 1999 but made an investment of ₱700,000.00 in Lemar General Trading Corporation, and that Marina Rose, who had just passed the Dental Board Examinations, made a ₱100,000.00 investment in Le Mar Dental Clinic in 1999. The CA concluded that the sources of the acquisitions and investments came from Leovigildo and that the properties were owned by him but registered under his children’s names to hide their ownership, and that Leovigildo failed to satisfactorily establish the legitimate source of income used in acquiring the subject properties.

• Ombudsman Authority: Petitioner argued that while he did not question the Ombudsman’s general authority to investigate and prosecute erring public officials, Section 10 of R.A. 6713 vests the specific and direct authority to review subordinates’ SALNs in heads of executive departments; the Commissioner of Customs therefore had authority over BOC employees’ SALNs, and the Ombudsman’s review, investigation, and corrective action violated R.A. 6713, encroached on the Commissioner’s authority, and disregarded the BOC guidelines on SALN review and compliance.
• Substantial Evidence: Petitioner maintained that the Ombudsman’s findings were not supported by substantial evidence and were grounded entirely on speculation, surmises, or conjectures.
• SALN Omissions: Petitioner admitted failing to report his Taal assets in his 1994, 1995, and 1996 SALNs but claimed this was an honest mistake that he voluntarily rectified in succeeding SALNs; he also argued that Marina’s ₱2,000,000.00 sweepstakes winnings were not among the assets required to be reported in his 1994 SALN.
• Penalty under BOC Guidelines: Petitioner argued that under BOC guidelines, failure to file or correct an erroneous SALN carries only suspension for one month and one day to six months on the first instance and dismissal from service on the second instance, and that such offense does not constitute Dishonesty or Gross Misconduct.
• Foreign Trips: Petitioner asserted that the Ombudsman failed to attach the Bureau of Immigration records supposedly proving seventy foreign trips and that the documents serving as basis for the claim were not attached to the Complaint.
• Children’s Capacity: Petitioner argued that the Ombudsman glossed over his children’s professional qualifications and other circumstances showing that they had the financial capacity to legitimately acquire the Disputed Assets attributed to him.
• Valuation: Petitioner argued that the FIO bloated his net worth by using the market values of the properties declared in his SALNs instead of their respective acquisition costs.

• Ombudsman Authority: Whether the Ombudsman may directly review a BOC employee’s SALNs and investigate discrepancies despite Section 10 of R.A. 6713 vesting SALN review in the head of office.
• Grave Misconduct: Whether Leovigildo’s failure to faithfully comply with the SALN requirement and acquisition of assets manifestly disproportionate to his lawful income constitute Grave Misconduct.
• Dishonesty: Whether substantial evidence supports Leovigildo’s administrative liability for Dishonesty based on manifest disproportion between his lawful income and the Disputed Assets and his concealment of those assets in his children’s names.
• Foreign Trips as Unexplained Wealth: Whether the alleged foreign trips may be considered proof of unexplained wealth absent the BI records and without a reasonable determination of their cost.

• Ombudsman Authority: Yes. Section 10 of R.A. 6713 does not strip the Ombudsman of its power to investigate and prosecute motu proprio; its power cannot depend on prior action by another office.
• Grave Misconduct: No. The SALN omissions and disproportionate assets had no direct relation or nexus to Leovigildo’s duties as Chief Customs Operations Officer, and the elements of Grave Misconduct were not present.
• Dishonesty: Yes. Substantial evidence showed assets manifestly disproportionate to lawful income and deliberate concealment in the names of children who lacked capacity to acquire them; malicious intent to conceal the truth was present.
• Foreign Trips as Unexplained Wealth: No. The BI records were not in the records, and the ₱30,000.00-per-trip estimate was arbitrary; without proof of cost, the trips could not be treated as unexplained wealth.

• Ombudsman Authority: Section 10 of R.A. 6713 vests upon heads of executive departments the authority to ensure faithful compliance with the SALN requirement, but it does not strip the Ombudsman of its sole power to investigate and prosecute, motu proprio or upon complaint of any person, any public official or employee for acts or omissions which appear to be illegal, unjust, improper, or inefficient. In Carabeo vs. Sandiganbayan, the SC held that the internal office procedure of calling a subordinate’s attention to SALN omissions is an internal office matter and cannot bar the Office of the Ombudsman from investigating the latter; the Ombudsman’s power to investigate and prosecute erring government officials cannot be made dependent on the prior action of another office, as that would diminish its constitutionally guarded independence. The fact that Leovigildo had not been previously placed under a BOC-sanctioned investigation did not make the Ombudsman’s acts void or premature, because the Ombudsman’s power to investigate and prosecute him on account of discrepancies in his SALNs stands independent of the Commissioner of Customs’ power to ensure compliance with the SALN requirement within the BOC.
• Grave Misconduct: Misconduct is an intentional wrongdoing or a deliberate violation of a rule of law or standard of behavior. Misconduct is grave where the elements of corruption, a clear intent to violate the law, or a flagrant disregard of established rules are present. To constitute Misconduct, the act or omission complained of must have a direct relation to the public officer’s duties and affect not only his character as a private individual but also, and more importantly, the performance of his official duties as a public servant. In Gupilan-Aguilar vs. Office of the Ombudsman, the SC held that owning properties disproportionate to one’s salary and not declaring them in the corresponding SALNs cannot, without more, be classified as grave misconduct, and that without a nexus between the act complained of and the discharge of duty, the charge of grave misconduct necessarily fails. Here, the acts and omissions for which Leovigildo was charged were not shown to have had an effect on his duties as Chief Customs Operations Officer; there was no direct relation or connection between the SALN omissions and disproportionate assets and the rendition of sound public service, so the charge of Grave Misconduct must fail.
• Dishonesty: Sections 7 and 8 of R.A. 3019 spell out the SALN requirement and lay down its scope. Section 7 requires every public officer to prepare and file a true, detailed, and sworn statement of assets and liabilities, including a statement of the amounts and sources of income, personal and family expenses, and income taxes paid. Section 8 provides that if a public official has been found to have acquired during his incumbency, whether in his name or in the name of other persons, an amount of property and/or money manifestly out of proportion to his salary and to his other lawful income, that fact shall be ground for dismissal or removal; properties in the name of the spouse and dependents may be taken into consideration when their acquisition through legitimate means cannot be satisfactorily shown. While mere omission from or misdeclaration in one’s SALN per se do not constitute Dishonesty, an omission or misdeclaration qualifies as such offense when it is attended with malicious intent to conceal the truth, as Dishonesty implies a disposition to lie, cheat, deceive, or defraud. Here, Leovigildo’s malicious intent to conceal the Disputed Assets was evident: he deliberately placed the Disputed Assets in the names of his children for the purpose of concealing them, and while he maintained that his children had the financial capacity to acquire the Disputed Assets, the evidence on record clearly showed otherwise. The CA painstakingly explained that Leo Gerald could not have afforded the Makati condominium payments given that he was licensed to practice dentistry only on January 3, 1994; that the supposed loan for the Muntinlupa property was undertaken 15 days after full payment; that the Toyota Land Cruiser was acquired in cash when Leo Gerald and his wife’s registered total annual net income was only ₱216,825.50; that Leovigildo, Jr. purchased the Ayala Alabang condominium when he was only 24 and still a law student, and the alleged trust was not supported by a declaration of trust filed with the Office of the Clerk of Court of Makati City as required by the Notarial Law; that Marie Antoinette and her husband had a total income of ₱374,083.50 in 1999 but invested ₱700,000.00 in Lemar General Trading Corporation; and that Marina Rose made a ₱100,000.00 investment in Le Mar Dental Clinic in 1999 after just passing the Dental Board Examinations. The SC, not being a trier of facts, accorded respect to the findings of the Ombudsman where they are supported by substantial evidence and have been affirmed by the CA. Since Leovigildo failed to satisfactorily show that his children had the capacity to acquire the Disputed Assets, the Ombudsman and the CA correctly concluded that the same were acquired by Leovigildo himself. When a public officer’s accumulated wealth is manifestly disproportionate to his lawful income and such public officer fails to properly account for or explain where such wealth had been sourced, he becomes administratively liable for Dishonesty. The disproportion between Leovigildo and Marina’s declared income of ₱10,841,412.28 and the acquisition cost of the Disputed Assets of ₱23,717,226.89 is too stark to be ignored. Under Section 52, Rule IV of the Uniform Rules on Administrative Cases in the Civil Service then in force at the time the Complaint was filed, Dishonesty was classified as a grave offense punishable by dismissal on the first instance, which penalty inherently carries with it cancellation of civil service eligibility, forfeiture of retirement benefits, and perpetual disqualification from re-employment in the government service.
• Foreign Trips as Unexplained Wealth: The disputed BI records which served as the Ombudsman’s proof of the De Castros’ alleged foreign trips did not form part of the records of the case, and the value the Ombudsman used to quantify the cost of these alleged trips, ₱30,000.00 for each trip, was a “conservative estimate” which the latter appeared to have arbitrarily assigned for expediency. Before a foreign trip taken by a public officer can be considered as proof of unexplained wealth, it shall first be necessary to establish that the cost thereof is, in fact, manifestly disproportionate to the latter’s lawful income. In Pleyto vs. PNP-Criminal Investigation and Detection Group, the SC refused to consider the foreign trips alleged to have been taken by respondent therein as proof of unexplained wealth for failure of the complainant therein to establish that the cost of these trips was beyond the former’s capacity to pay; the SC held that travel records from the BID could only establish the details on the trips taken, such as dates of departure and arrival, destination, and frequency, and that it was a long jump to conclude just from the BID travel records that the foreign travels were beyond the financial capacity of the petitioner and his wife. The investigating officers, in fixing the amount of all the foreign trips at ₱100,000.00 each, offered no explanation or substantiation for the same; with utter lack of basis, the figure was random and arbitrary and, thus, unacceptable. Without a reasonable estimation of the costs of the foreign travels, there is no way to determine whether these were within their lawful income. Proceeding therefrom, the SC found that the CA erred when it considered the Ombudsman’s findings regarding the De Castros’ alleged foreign trips as established facts, in the absence of substantial evidence showing that such trips were in fact taken and that it was reasonable to peg the total cost of these trips at ₱2,100,000.00. Nevertheless, this did not negate the finding of Dishonesty based on the manifest disproportion between Leovigildo’s lawful income and the Disputed Assets.

• Ombudsman’s Independent Investigatory Power — The Ombudsman may investigate and prosecute public officials motu proprio or upon complaint; Section 10 of R.A. 6713’s internal SALN review by heads of offices is not a condition precedent and does not diminish the Ombudsman’s constitutionally guarded independence. Applied: the Ombudsman could directly review Leovigildo’s SALNs despite the Commissioner of Customs’ authority over BOC employees’ SALNs.
• Grave Misconduct — Misconduct is intentional wrongdoing or a deliberate violation of a rule of law or standard of behavior; it is grave when corruption, a clear intent to violate the law, or a flagrant disregard of established rules is present. The act or omission must have a direct relation to the public officer’s duties and affect the performance of official duties. Applied: SALN omissions and unexplained wealth without a nexus to Leovigildo’s customs duties did not constitute Grave Misconduct.
• Dishonesty in SALN — Mere omission or misdeclaration in a SALN is not per se Dishonesty; it becomes Dishonesty when attended with malicious intent to conceal the truth. Dishonesty implies a disposition to lie, cheat, deceive, or defraud. Applied: Leovigildo deliberately placed disproportionate assets in his children’s names to conceal them.
• Unexplained Wealth under R.A. 3019 — Sections 7 and 8 require a true, detailed SALN and treat property acquired during incumbency, whether in the official’s name or in the name of other persons, manifestly out of proportion to salary and other lawful income as ground for dismissal; properties in the name of spouse and dependents may be considered when acquisition through legitimate means cannot be satisfactorily shown. Applied: the Disputed Assets in the children’s names were attributed to Leovigildo because their legitimate acquisition was not shown.
• Foreign Travel as Proof of Unexplained Wealth — Before foreign travel can be considered proof of unexplained wealth, the cost of the trips must first be established and shown to be manifestly disproportionate to lawful income; arbitrary estimates without substantiation are unacceptable. Applied: the ₱30,000.00-per-trip estimate and missing BI records could not support an unexplained wealth finding.

• “Its power to investigate and prosecute erring government officials cannot be made dependent on the prior action of another office. To hold otherwise would be to diminish its constitutionally guarded independence.” — The SC used this passage from Carabeo vs. Sandiganbayan to reject the argument that the Ombudsman must await the BOC’s SALN review before investigating Leovigildo.
• “Misconduct is grave where the elements of corruption, a clear intent to violate the law, or a flagrant disregard of established rules are present.” — The SC applied this test to hold that Leovigildo’s acts did not amount to Grave Misconduct because there was no nexus to his official duties.
• “While mere omission from or misdeclaration in one’s SALN per se do not constitute Dishonesty, an omission or misdeclaration qualifies as such offense when it is attended with malicious intent to conceal the truth, as Dishonesty implies a disposition to lie, cheat, deceive, or defraud.” — This is the ratio for affirming Leovigildo’s liability for Dishonesty based on deliberate concealment of the Disputed Assets.
• “Without a reasonable estimation of the costs of the foreign travels of petitioner and his wife, there is no way to determine whether these were within their lawful income.” — The SC used this passage from Pleyto vs. PNP-Criminal Investigation and Detection Group to reject the Ombudsman’s arbitrary ₱30,000.00-per-trip estimate.

• Carabeo vs. Sandiganbayan, 659 Phil. 40 (2011) — Controlling precedent; held that Section 10 of R.A. 6713’s internal SALN review does not bar the Ombudsman from investigating a public officer.
• Gupilan-Aguilar vs. Office of the Ombudsman, 728 Phil. 210 (2014) — Controlling precedent; held that disproportionate properties and SALN non-declarations without a nexus to official duties do not constitute Grave Misconduct; also cited on malicious intent for Dishonesty.
• Pleyto vs. PNP-Criminal Investigation and Detection Group, 563 Phil. 842 (2007) — Controlling precedent; held that foreign travel records and arbitrary cost estimates cannot establish unexplained wealth without proof of actual cost.
• Abulencia vs. Hermosisima, 712 Phil. 248 (2013) — Cited for the definition of misconduct.
• Dumaguete CLC Lending Corp. vs. Tubilla, A.M. No. P-15-3343, August 3, 2015 — Cited for the definition of Dishonesty as a disposition to lie, cheat, deceive, or defraud.
• Bulos, Jr. vs. Yasuma, 554 Phil. 591 (2007) — Cited for the respect accorded to the Ombudsman’s factual findings when supported by substantial evidence and affirmed by the CA.
• Casimiro vs. Rigor, G.R. No. 206661, December 10, 2014, 744 SCRA 611 — Cited on the constitutionalization of public accountability and public office as a public trust.
• Ambray and Ambray, Jr. vs. Tsourous, G.R. No. 209264, July 5, 2016 — Cited for the exceptions to the Rule 45 rule that only questions of law may be raised.

• Section 10, R.A. 6713 — Review and compliance procedure; heads of offices ensure SALN compliance. The SC held it does not strip the Ombudsman of its power to investigate and prosecute.
• Sections 7 and 8, R.A. 3019 — SALN requirement and prima facie evidence of unexplained wealth; applied to the manifest disproportion between Leovigildo’s lawful income and the Disputed Assets, and to properties in the names of dependents.
• Section 52, Rule IV, Uniform Rules on Administrative Cases in the Civil Service (CSC Resolution No. 991936) — Classified Dishonesty as a grave offense punishable by dismissal on the first instance, with cancellation of civil service eligibility, forfeiture of retirement benefits, and perpetual disqualification from re-employment; the penalty was affirmed.
• Rule 45, Rules of Court — Petition for review on certiorari; general rule that only questions of law may be raised, subject to recognized exceptions; the SC reviewed the findings because the petition invoked exceptions.
• Section 22, Omnibus Rules Implementing Book V of Executive Order No. 292 — Basis for the administrative complaint for Dishonesty, Grave Misconduct, and Conduct Prejudicial to the Best Interest of the Service.