Concepcion C. Daplas vs. Department of Finance
Concepcion C. Daplas vs. Department of Finance
Concepcion C. Daplas vs. Department of Finance
DEPARTMENT OF FINANCE
The Court found petitioner GUILTY of SIMPLE NEGLIGENCE in accomplishing her SALN for the years
1997 to 2003. Records reveal that the element of intent to commit a wrong required under both the
administrative offenses of Dishonesty and Grave Misconduct are lacking to warrant petitioner's dismissal
from service.
The Court finds that there is no substantial evidence of intent to commit a wrong, or to deceive the
authorities, and conceal the other properties in petitioner's and her husband's names. Petitioner's failure to
disclose in her 1997 SALN her business interest in KEI is not a sufficient badge of dishonesty in the absence
of bad faith, or any malicious intent to conceal the truth or to make false statements.
Indeed, the failure to file a truthful SALN puts in doubt the integrity of the public officer or employee, and
would normally amount to dishonesty. It should be emphasized, however, that mere non-declaration of the
required data in the SALN does not automatically amount to such an offense.