• By The Financial District


The Court of Appeals (CA) has affirmed the dismissal from the government service of a customs operations officer found liable for serious dishonesty in making false declarations in her annual Statements of Assets, Liabilities and Networth (SALNs).

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Miriam Casurayan, a Customs Operations Officer III in the BOC, was found liable by the appellate court for failure to declare ownership of a house and lot in her SALNs seven times.

The court’s decision dated October 23, 2020, was based on an investigation done by the Revenue Integrity Protection Service (RIPS), which is the anti-corruption arm of the Department of Finance (DOF).

Finance Undersecretary for legal affairs Bayani Agabin said the DOF and the Bureau of Customs (BOC) will swiftly implement the CA decision, in step with President Duterte’s heightened campaign against official corruption.

The DOF-RIPS found out that Casurayan purchased a property located in San Jose Del Monte, Bulacan in 1998, but deliberately omitted declaring it in her subsequent SALNs. The DOF-RIPS then filed a case against Casayuran before the Office of the Ombudsman based on these findings, but the complaint was dismissed.

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On appeal by the DOF-RIPs before the CA, the court’s Eighth Division ruled that Casayuran’s failure to declare the Bulacan property in her SALN not only once but for seven years that she was in the service, was a deliberate omission.

The CA, citing the case of Fajardo vs Corral, said in its decision dated Oct. 23, 2020, that “Dishonesty is defined as the ‘concealment or distortion of truth, which shows lack of integrity or a disposition to defraud, cheat, deceive, or betray, or intent to violate the truth. Thus, the mere omission from or misdeclaration in one’s SALN does not per se constitute Dishonesty. Only when such omission or misdeclaration is attended by malicious intent to conceal the truth can it be said to constitute dishonesty.

Aside from dismissing her from the service, the court also ordered the cancellation of Casayuran’s civil service eligibility, her disqualification from taking civil service examinations, forfeiture of her retirement benefits, and perpetual disqualification from holding public office.

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The CA ruling was received by the DOF-RIPS on January 11, 2021.

“As a government employee, it is incumbent upon Casayuran to provide truthful disclosures in her SALNs. As discussed by the Honorable Court in its decision, the full disclosure of one’s wealth in SALNs is a means of preventing and curtailing corruption and maintaining a standard of honesty in the public service,” said Agabin, who supervises the DOF-RIPS.

The DOF-RIPS earlier launched the Information Against Corruption page which can be accessed using the URL https://www.dof.gov.ph/report-corruption. The move is in support of President Duterte’s more intensified drive against graft and corruption during the remainder of his term.

Informants may submit evidence through this “Sumbong” page showing properties or lifestyles grossly disproportional to the pay levels of officials and employees of the DOF and its attached agencies.

The DOF-RIPS has initiated investigations against 403 officials and employees of the DOF and its attached agencies since President Duterte took office in 2016.

Its anti-corruption probes have led to the filing of administrative and/or criminal cases against 60 errant public officers, of which 14 have already been dismissed from the service.

Finance Secretary Carlos Dominguez III has ordered the DOF-RIPS to coordinate with the Task Force Against Corruption led by the Department of Justice (DOJ) to discuss how the two departments can work together in weeding out graft and corruption in the bureaucracy.


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