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Administrative Accountability

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Administrative Accountability

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Bluebook 21st ed.


Ledivina V. Carino, Administrative Accountability: A Review of the Evolution, Meaning
and Operationalization of a Key Concept in Public Administration, 27 PHIL. J. PUB.
ADMIN. 118 (1983).

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Ledivina V. Carino, Administrative Accountability: A Review of the Evolution, Meaning
and Operationalization of a Key Concept in Public Administration, 27 Phil. J. Pub.
Admin. 118 (1983).

APA 7th ed.


Carino, L. V. (1983). Administrative Accountability: Review of the Evolution, Meaning
and Operationalization of Key Concept in Public Administration. Philippine Journal of
Public Administration, 27(2), 118-148.

Chicago 17th ed.


Ledivina V. Carino, "Administrative Accountability: A Review of the Evolution,
Meaning and Operationalization of a Key Concept in Public Administration," Philippine
Journal of Public Administration 27, no. 2 (April 1983): 118-148

McGill Guide 9th ed.


Ledivina V. Carino, "Administrative Accountability: A Review of the Evolution,
Meaning and Operationalization of a Key Concept in Public Administration" (1983) 27:2
Phil J Pub Admin 118.

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Ledivina V. Carino, 'Administrative Accountability: A Review of the Evolution,
Meaning and Operationalization of a Key Concept in Public Administration' (1983) 27
Philippine Journal of Public Administration 118.

MLA 8th ed.


Carino, Ledivina V. "Administrative Accountability: A Review of the Evolution,
Meaning and Operationalization of a Key Concept in Public Administration." Philippine
Journal of Public Administration, vol. 27, no. 2, April 1983, p. 118-148. HeinOnline.

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Ledivina V. Carino, 'Administrative Accountability: A Review of the Evolution,
Meaning and Operationalization of a Key Concept in Public Administration' (1983) 27
Phil J Pub Admin 118

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PhilippiheJournalof PublicAdministration, Vol. XXVII, No. 2 (April1983)

Administrative Accountability: A Review


of the Evolution, Meaning and
Operationalization of a Key Concept in
Public Administration
LEDIVINA V. CARII4O*

Administrative accountability may be defined as the evolution of the actions of ap-


pointed careeremployees and officials in terms of whether their actions are within or out-
side the bounds of their authority. The concept has exhibited varying concerns and
emphases over the years Four variants of accountability may be distinguished on the
following dimensions: who is considered accountable, to whom he is accountable, the
standards or values he is accountable, and the means by which he is accountable. These
are: traditionalaccountability which focuses on the regularity of fiscal transactionsand
faithful compliance as well as adherence to legal requirements and administrativepolicies;
managerial accountability which is concerned with efficiency and economy in the use of
funds, property, manpower and other resources," program accountability which pays
attention to the results of government operations; and process accountability which
emphasizes procedures and methods of operation.Relating accountability with Public
Administration theory, a congruence of concerns is found in the types of accountability
and the varieties of Public Administration.Accountability may be promoted through the
imposition of external controls and through the inculcation of self-regulating value& The
use of power, discretioY4 the processes of employee behavior regulation such as contro4
supervision, influence and management and other extra-bureaucraticvalues bear upon
accountability. There is an increasingreliance on program content and participatorypro-
cedures, and stress on negotiation and even self-determinationof standards of accounta-
bility. Despite these changes, however, problems of graft and corruption and the in-
congruenceof official actions with public interestremain.

A public office is a public trust. Public officers and employees shall serve
with the highest degree of responsibility, integrity, loyalty and efficiency and
shall remain accountable to the people.

Constitution of the
Philippines, 1973
Article XIII, Section I

*Professor and Dean, College of Public Administration, University of the Philippines.


The author is grateful to her students in PA 303 (Administrative Models of Development),
second semester, 1982-83, on whom the initial ideas embodied in this paper were first inflicted and
whose reactions helped to clarify and bring up important points; to Salahuddin Aminuzzaman
who provided useful research assistance and to Professors Aurora C. Catilo, Ma. Concepcion P.
Alfiler and Leonor M. Briones who commenLed ,onearlier drafts.
ADMINISTRATIVE ACCOUNTABILITY 119

Introduction
Accountability is a central problem for governments which are, or claim
to be, democratic. The activities of civil servants and public agencies must
follow the will of the people to whom they are ultimately responsible. The
publicness of their employment and goals thus prescribes their behavior and
circumscribes their choices. Nevertheless, all individuals and offices continue
to have a range of options as to how they would act. The evaluation of whether
such action would be within or out of the bounds of their authority is the
referrant of the concept of accountability. I shall focus my discussion on
administrative accountability, that is, the level of appointed, usually career
employees and officials. The accountability of elected officials and of the policies
emanating from them is no less important; unfortunately, that raises other
major issues that would require a separate paper.
While accountability is at the core of democratic theory, and one would
wish, of practice also, it has not been quite as central in the discipline and
teaching of Public Administration.' The literature relating the public service
to democracy is not voluminous. 2 Brown and Craft in decrying the "unrealized
partnership of auditing and of Public Administration" blame the near-idolatry
of Lasswell's process of "who get what, when and how," to a near neglect in
schools of Public Administration,3
to show "what" is spent, how it is reported
and what have been its impacts.
Their complaint is instructive and serves to point out how unevenly Public
Administration has treated the three phases of the classical cycle of adminis-
tration-planning, implementation and evaluation. Planning, including the
Lasswellian slogan and the study of other inputs, received disproportionate
attention in traditional Public Administration. Implementation came into its
own much later. Evaluation is more of an afterthought, sometimes taught
along with survey methods and rarely transferring from the realm of meth-
odology into substance. Ethics itself, one of the values that can increase the
sense of accountability, has been treated as if its discussion is threatening to
the doctrine of the separation of church and state (a fundamental tenet that
safeguards freedom of worship and thus thinking and belief). In the College of
Public Administration (CPA), University of the Philippines (UP), Ethics was
dropped as a course in the curriculum more than two decades ago.
This paper is an attempt to realize the partnership not only of Public
Administration and auditing but also of Public Administration and democratic
theory. If the people are indeed the masters of this society, their means of
maintaining that supremacy must be scrutinized and sharpened. These means
are embodied in the forms and standards of accountability which, however,
have not remained static over time. Rather, they have undergone what may be
regarded as an evolution so that now one can contrast "traditional" account-
ability with new variants. A description of these variants would be useful in
understanding how and in what directions standards are changing and how
they are related to the promotion and protection of the public interest.

1983
,120 PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

The changes do not represent mere -technological advancement in auditing


and other techniques of evaluation. Rather they are responsive to the social
and political forces that vary with a country's development. 4 As Fosher states:
"As the public becomes better educated, they also become more aware, more
demanding, less understanding and less willing'to accept average performance
from governments.' 5 Are the modifications of the mode of evaluation then better
able to meet these new dpmands? Or is the proliferation of new terms and new
techques a dAizzymng .exercise which makes 'bureaucracies more intractable
and less subject 'popular direction? The changes in the concept of accountability
an'be illumined by putting them in the context of the changes in the discipline
of Public Administration which in turn have been 'ifluenced by specific
academic currents aswell as'broad societal forces.
In addition, I shall study how accountability is- maintained from the
viewpoint of the administrator in the bureaucracy. The use of the process of
power seems to vary with the kind of accountability adhered to,by the bureau-
cratic superior.
-'Finally, since. accountability is ultimately to the people, I shall evaluate
how the evolution has affected the protection of the people's interest. Since the
trend has been from an emphasis on compliance to a: stress on iegotiations,
an important remaining query is if and how the increasing openendedness can
lead to the decrease of problems such as graft and: corruption and to the
greater congruence of official actions with the public interest.

The Types of Accountability


* Four standard questions arelentral to accountability:
(1) Who is considered accoumitable?
(2) To whom is he accountable?
(3) To what standards or values is he accountable?
((4) By what means is he made accountable?
The type of accountability differs, depending on the answers to these queries.
I 'shall distinguish among four kinds-traditional, managerial, program and
process accountability.

TraditionalAccountability
T aditional accountability focuses on the regularity of fiscal transactions
and the faithful compliance as well as adherence to legal requirements and
administrative policies. Traditional accountability is a responsibility of the
bureaucrat who has been given the authority to discharge a particular function
as an expression of hierarchically-ordered legal responsibilities. 6 It is owed to
superiors in the bureaucracy and especially the legislature and the courts
which may inquire into a person's exercise of his duties.

April
ADMINISTRATIVE ACCOUNTABILITY

The standards by.which one is judgedare those of legality and regularity


which are set by controllers external to the person responsible. The test of
legality involves determining if an act is within the provisions of laws and.
regulations governing the agency, and if the person or persons who performed it
have the authority to do so.'In order to attain its objectives according to law
and to safeguard the use of public resburces, each agency sets up procedures'
for each transaction and, following the Weberian rule, expects these procedures'
to befollowed fairly and equitably, without regard to the individual character-
istics of the clients interested in the transactions. To aid in this quest for
universalism, areas of bureaucratic discretion are. circumscribed, the rest
becoming routine, i.e,, a programmed, regularly followed (and often detailed)
method of procedures.
These procedures are themselves an important means of insuring tradi-
tional accountability, along with line-item budgeting and financial accounting
and auditing. Pre-auditing by the supreme, auditing agency was a traditional
tool and as such, indorsed the control by an external institution of basically
internal management processes.'

ManagerialAccountability
Managerial accountability concerns itself with "efficiency and economy
in the use of public funds, property, manpower and other resources." 7 As its
name implies, the person accountable is the manager, and.he is responsible to
his superiors in the bureaucracy, the President and external controllers such as
the legislature which provides the resources for,the'operations of. the agency.
It recognizes that government officials -are responsible for more than just,
compliance. It .focuses- on the input side and suggests the need for constant
concern in order to avoid waste, and unnecessary expenditures-and topromote
the judicious -use .of public resources. The main, values,.-as.already stated, are
economy -and efficiency, and'involve a comparison of costs against output.:
Leo Herbert provides a, useful definition of and differentiation between the
two standards:. . .
Efficient operations include: (1)holding the costs constant while increasing
the benefits, .(2).holding the benefits constant while decreasing the-costs,
.(3) increasing the costs at a slower rate than benefits, and (4) decreasing
costs at a lower rate than benefits. Economical operationt is the elimination
or reduction of needless costs. Thus, economy and efficiency, as they both
pertain to reduction or elimination of costs, are equivalent in meaiings.
Only when costs remain constant or increase in relatidn to increasming benefits ' -,
are the meanings different.8
Managerial accountability is promoted by programs which cut the red tape
of government procedures or which substitute less costly -alternatives to
existing practices. These programs range from attempt at work simplification
and revision of forms all-the way to systms improvement and agency reorgan.-
ization. Most of these innovations can e 'done by agency officials. In additioi;
an agency may be the subject'of an operational or management audit-,Which

1983
122 PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

may be conducted by an external independent agency such as the Management


Office of the Office of the Budget and Management (OBM) or the Commission
on Audit (COA).
At present, COA conducts audits as part of its 3E's auditing (that is,
economy, and efficiency plus effectiveness) for selected agencies. Many of its
findings bear an economy and efficiency. The reports on the 1981 3E's for
selected public enterprises found certain problems related to fiscal management
and even personnel administration such as:

(1) System of collecting accounts receivables is deficient in at least two


corporations, such accounts together amounting to over P6 million.
(2) Investment funds amounting to P61 million are not adequately
are uncollected upon maturity in at least four public enterprises.
are collected upon maturity in at least four public enterprises.

(3) In-one trading corporation, a dental chair worth P130,000 was purchased.

(4) In another, equipment worth 90,000 stands idle because of the


non-hiring of technical men to operate it.

These difficulties are only examples. Comments on the 3E's were totally
favorable in only two agencies.

Operational audits had long been done by agencies concerned with manage-
ment, under such names as management analysis, organization and methods
(0 and M) studies and systems improvement. They were institutionalized with
the creation of the then Institute of Public Administration, UP in 1952 and the
establishment of the Management Service under the Budget Commission in
1958, the latter following the recommendation of the Government Survey and
Reorganization Commission (GSRC). The GSRC was in turn charged with the
restructuring of the bureaucracy "in order to insure the economy and efficiency
of operations." These institutions of the fifties continue to exist under new
names. They have been joined by other government agencies such as the
Development Academy of the Philippines (DAP), other schools of both public
and business administration and a host of management consultancy firms
from the private sector (these growing out of both the accounting and engineering
professions), all calling attention to how government agencies can reduce waste
and effect savings in their operations.

ProgramAccountability
Program accountability is concerned with the results of government
operations. As such, accountability is the property of units as well as of individual
bureaucrats whose activities together make for the effectiveness of a program.
Although external agents like the legislature may inquire into what a program

April
ADMINISTRATIVE ACCOUNTABILITY

accomplishes, the main focus of this type of accountability is really the head of
the agency as manager'of its programs. To secure its attainment, a number of
means are available. First is comprehensive or performance audit, which unlike
fiscal audit, is performed on a non-regular basis. It is an objective examination
of the financial and operational performance of an organization as program
and uses the standard of the 3E's. A complete performance audit involves
inquiry into the following:
(1) Whether the government unit is carrying out only authorized activities
or programs and is carrying them out in the manner contemplated, and
whether they are accomplishing their objectives. The auditors should
determine whether the authorized activities or programs continue to
serve effectively their originally intended purpose;
(2) Whether the programs and activities are conducted and expenditures
are made in an effective, efficient and economical manner and in com-
pliance with the requirements of applicable laws and regulations;
(3) Whether resources are being adequately controlled and used effectively,
efficiently and economically;
(4) Whether all revenues and receipts from the operations under exam-
ination are being collected and properly accounted for;
(5) Whether the entity's accounting system complies with applicable
accounting principles, standards and related requirements; and
(6) Whether the entity's financial statements and operating reports prop-
erly disclose the information required.9
Befitting its emphasis as a help to the administrator, the other modes for
attaining program accountability are management tools such as the construc-
tion, use and analysis of productivity and work measures, program evaluation
and cost-benefit analysis as well as broad-based organizational changes like
management by objectives (MBO) and Organizational Development (OD).
Social Accountability. Recently, the program managers' arsenal has been
augmented by such tools as human resource accounting, social accounting and
the analysis of economic and social impact of programs. These operationalize
a variant of program accountability known as "social accountability" in which
the main inquiry is whether the administrative activities "inspire general
confidence and secure what are widely regarded as desirable social end." 10
The manager also seeks to satisfy the interest of the citizen not only in an
ultimate sense (through the hierarchy and the external agents) but also in the
handling of the programs in a manner more directly benefitting him.

ProcessAccountability
Process accountability as its name implies emphasizes procedures and
methods of operation and focuses on the black box inside systems which
transforms inputs (the concern of traditional and managerial accountability)
to outputs (the concern of program accountability). This type of accountability
recognizes that some goals may not be measurable directly and surrogates

1983
PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

representing: hw goal-directed activity may 'e performed are used instead.


For instance, the health of a village may be indexed by percentage of children
inbeulated, proportion of mothers provided pre- and post-natal care, and the like.
If ahealth of clinic has a high batting average on these targets, one can then
make the judgment that it has been behaving responsibly.

There is a danger that indirect measurement may degenerate into a


numbers-game where an evaluator simply counts inoculations and consulta-
tions. To ioid this, the concept may be'enhan'ced by using McKinney's
adaptation of process accountability into specifically democratic and political
settings. His uggestion is to deliver a public good or service only after

both providers and recipients have met together to agree in advance regard-
ing the.actions, processes or steps that will be followed prior to delivery of
the qudity, quaptity, ,time, manner, and,place of the proposed goods or
services., Those responsible for providing the service are expected to perform
according to agreed-upon terms and with stipulated use of resources based
on specific performance standards. Likewise, recipients (participants) must
agree to accept in advance specific rewards or costs based on 11
an evaluation
of the appro ximtion of planned ends to attained outcomes.
Accountability can then*be asked of both provider and recipient and
standards of judgment are themselves products of the mutual agreement.
Each side may withhold its part of the bargain when the other fails the
accountability-test.

A discussed by McKinney, process accountability is directly applicable to


intergovernmental relations especially in the provision of grants by the central
government to o'I levels where conditions for funding and service are nego-
tiated by both parties. A similar procedure is embodied in the recommendations
of,.th , Canadian Royal Commission on Finncial Management and Accountability.
This body, known popularly as the Lambert Commission,'endorses the concept
of.'-responsibility accounting," a private sector approach; the basic feature of
which is to delegate authority extensively to divisional or branch managers
2
who negotiate these'divisional ortargets with top management.'

Summary .
The concept of administrative accountability has clearly evolved over time
&long the four queries posed 'in the beginning. This -is tabulated for easy
referende in' Figure I. The "who" in a sense is the one that has changed least,
since officials and 'employees are considered accountable in all four types.
Note, however, that increasingly, the manager is seen as the accountable officer
who is responsible not only for his own conduct but also for the performance of
his entire agency. It may also be inferred that he can continue to exact traditional
accountability from-the employees under him at the same time that he views
not specific items but the operations of the whole program. Under process
accountability, the decentralized set-up 'uts, under scrutiny not only the
program adiuinistratorhimself but also the fund-giver.

April
ADMINISTRATIVE ACCOUNTABILITY 125

Figure I. Comparison of Different Kinds of Administrative Accountability

Traditonal Managerial Program Pmocess


Accountability Accountability Accountability Accountability

Who is accountable? Employees and Administrator Administrator Administrator


officials
To whom is he People through Same as Col. 1 Same as Col. 1 Same as Col. 1
accountable? legislature, Pres- Others: Profes- Others as in
ident, Constitu- sional Standards Col. 3
tional bodies, and individual Direct account-
hierarchy conscience ability to people
thru their partic-
ipation in nego-
tiation
To what standard Regularity, Economy and Economy, effi- 3 Es plus de-
of values is he legality and efficiency ciency and effec- centralization
accountable? compliance tiveness (3 Es) and participatn
By what means is Line-item budg- Management Comprehensive Negotiations
he made account- eting, traditional audit, systems audit, program
able? accounting, improvement evaluation,
standard operat- productivity
ing procedures measurement

The ultimate focus of accountability, the people, remains despite the


evolution. However, what are accepted as the people's surrogates have varied.
Elected representatives in the legislature and the President are supposed to
embody the people's will. When the Assembly, as now, does not have strong
investigative committees, its function as a body to which one is answerable is
weakened. The President remains a strong force. Courts which by their nature
are judging bodies try cases in which accountability is supposed to have
been breached, again as an agent of the state and thus, of the people. Agencies
external to line ministries which regulate conduct of officials-especially when
they are constitutionally ordained, like the COA, Civil Service Commission
(CSC, Tanodbayan (the Ombudsman) and Sandiganbayanare supposed to act
as watchdogs for the people under all accountability types. In all cases,
each higher level of the hierarchy can extract performance from its subordinates.

Increasingly, however, new surrogates gain entry as foci of accountability.


Program accountability legitimizes professional standards and individual
conscience as additional forces to which one can devote loyalty. Process
accountability involves the public, especially the local community where
programs are administered, as direct focus.

Standards and values have differed-from regularity and compliance to


rules and laws under traditional, to economy and efficiency under managerial
accountability. Program accountability adds the third E of effectiveness.

1983
126 PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

Effectiveness is carried over into process accountability, the last enshrining


decentralization and participation as values supplementary to the 3E 's.
Each type of accountability is seen to favor a different set of means.
Traditional accountability uses line item budgeting, pre-audit and other forms
of traditional accounting. It limits discretion and relies instead on programmed
choices. Managerial accountability utilizes operational auditing, systems
improvement and analyses of cost-saving techniques. Program accountability
introduces comprehensive audits, social accounting and tools for enhancing
productivity and program evaluation. Process accountability continues the
use of the performance standards of program accountability but makes their
use contingent on negotiations between the controller and the controlled.
The notion of administrative accountability has clearly changed. In a sense,
much more is expected of the accountable official in the later modes since his
responsibility is not for individual activities but for related sets as these are
divided into programs and projects. At the same time, the means to be used for
insuring his proper behavior have become less rigid, and more negotiable.

The Varieties of Public Administration


To further understand why the concept of accountability has been altered,
it would be useful to review changes in Public Administration (PA) theory over
time. While accountability has not been as extensively studied in PA as one
might wish, the forces that lead to changes in its meaning are similar to those
affecting PA. I shall first discuss each variety of PA and then proceed to put
each kind of accountability within the most appropriate school of Public
Administration.
Each of the four varieties of PA offers a distinct emphasis and relates to
the people and the society in a different way. They may be identified as
"traditional public administration," "development administration," "new
public administration" and "development public administration." The labels
of the first three varieties are rather well-known and their characteristics are
easier to identify. There is however, no set term for the last variety which has
also been called, by various authors, as "social conscience administration,"
"social development management," "development administration for equity,"
and the like. The package of characteristics combined under each variety will
be made clearer and more acceptable in the subsequent discussion.

TraditionalPublic Administration
The main emphasis of traditional PA, which was the prevailing school
until the early post-World War II period, is maintenance. Where any change
was contemplated, the role of public servants was how to implement decisions
made elsewhere by policy makers who were not in the bureaucracy. It had a
set of prescriptions laid down by engineers and managers who where obsessed
by the search for the one best way. In the Philippines, the Wilsonian task for

April
ADMINISTRATIVE ACCOUNTABILITY 127

public administration-i.e., running a Constitution-was eagerly embraced by


the Americans who wanted a neutral civil service; the politics-administration
dichoomy it implied was carried over into the early years of the postwar
13
period.
Attention focused on the internal organization; the society in which
it existed was a neglected variable. Thus, economy and efficiency of operations
appear to be the most important goals. If costs are low relative to output,
the output would be justified.

Teaching in traditional PA centered on the inputs to the system. Thus, the


main resources became the major focus of subfields-personnel administra-
tion, fiscal administration and organization and management. The implied
hypothesis was that satisfactory performance of the staff functions would lead
to a better public administration. Little or no attention was given to the im-
plementation of programs and the delivery of services.
As a variety in the discipline, traditional PA constituted the main doctrine
until the late fifties. As an actual activity, many of its main features persist to
this day.

DevelopmentAdministration
Development administration (DA) is the variety that gained currency
when colonies got political independence and set their sights on the develop-
ment of the economy following the example of the West. Closely related to
Comparative Administration, it is directed to the study of the countries called
the Third World. The main task of DA is the search for theories that can
describe and explain the management of economic growth. Universal
principles of traditional PA gave way to attempts at formulating middle-range
theories and the generation of case studies which showed the bureaucracy not
as idealized but as existing. Behavioralism, logical positivism, structural-
functionalism and quantification entered the discipline through the influence
of the social sciences especially sociology and economics.

With the Western experience as the model, DA became involved in looking


for tools that can improve the planning process and the performance of staff
functions. Not surprisingly, many of the tools were borrowed wholesale from
the West. Their adoption was marked by formalism. Culture became an
important explanatory variable and was often viewed as a hindrance to the
attainment of Western style development.

Despite interest in the ecology of public administration and social change,


DA was viewed largely as an independent variable in the society and relations
with it were seen as unidirectional. For instance, the Bell Mission which in a
sense ushered in DA in the Philippines, saw the civil service as the culprit in
the nation's slow development and recommended the creation of the Institute

1983
128 PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

of Public Administration as one answer to that problem. DA continued to


focus on the internal organization, and economy and efficiency remained as the
main evaluatory concepts. It is instructive that although the United States did
not have a DA period in its history, the main techniques of its (traditional) PA
were imported to the Philippines for use in the latter's own development
efforts. This included management tools like Planning, Programming, and
Budgeting System (PPBS), the first use of which was for military purposes in
Vietnam. Perhaps this serves to reinforce the DA notion of a value-neutral
discipline and value-free techniques.

New Public Administration


New Public Administration (New PA) was born in the seventies in a
United States of restive scholars who found traditional PA largely irrelevant
to a turbulent technological society crying for equity and social justice. Amer-
ican PA was hardly touched by DA except as the comparison society against
which "development" in the "less developed countries" was measured. Al-
though New PA was a particularly American phenomenon concerned with its
peculiar problems, it criticisms of PA, its search for alternatives to bureau-
cracy, its outrage at the continuing inequity and its rejection of a value-neutral
discipline, struck at responsive chords in the former colonies. Part of its
acceptability is faddistic, but a major part may be traced to the desire to put
Public Administration in the context of the society with its exploitative social
structure, to develop programs that can meet human needs. New PA advoca-
ted project management and the modular organization in heu of the bureau-
cracy. It either moved away from economics to philosophy, or sought a
blending of both. Just prior to the birth of New PA, Public Administration
scholars discovered implementation and service delivery as just as worthy of
attention as planning and the merit system. These blended to make respon-
siveness and effectiveness of programs as the main foci of concern.

Development PublicAdministration
The fourth variety is what I will call, for want of a better term, Develop-
ment Public Administration (DPA). The product of the 1980's, DPA is
similar to New PA in its emphasis on the goals of social justice, equity and the
centrality of the human person, and is akin to DA in its focus on the problems
of the Third World rather than the United States. DPA advocates do not
choose between equity and growth but view continued productivity as the
base upon which basic needs would be provided for everyone in the society and
benefits would be distributed in a more equitable way. Like New PA, DPA
locates public agencies in the context of their own societies and regards their
activities as complemented by, if not actually incomplete or inadequate
without, the empowerment of the people as participants in hne process of
administration.

April
ADMINISTRATIVE ACCOUNTABILITY lZ

In contrast to both DA and New PA, DPA locates its bureaucracy not
only within its own society but also in the context of a global system which
impinges on and constrains the policies of the nation, an often pernicious
linkage that was glossed over by writers of the DA period and hardly pertinent
to those of New PA who were after all focusing only on one of these key con-
trolling nations.

DPA is not just a newer form of New PA because it also takes many
elements from traditional PA. For instance, like DA and unlike New PA, it is
not against bureaucracy as an organization. In fact, one of its main programs
involves not the toppling of large-scale hierarchical structures but of their
modification through bureaucratic reorientation, the change not of structures
but of the people within. However, like New PA, it searches for smaller,
possibly ad-hoc, organizations for trying out new approaches, for coordinating
the activities of similar agencies, and for involving those outside the organiza-
tions in planning, implementation and evaluation.

Another point of contact with traditional PA is the concern for


maintenance and continuity. While not rejecting project management which
New PA stressed, the concern of DPA is the infusion of new life into regular
long-term programs by organizations which acknowledge and learn from their
mistakes.
Particularly in the Philippines, an important aspect of DA is decentraliza-
tion, a value re-emphasized by DPA as it seeks harmony between central direc-
tion and responsiveness to particular needs. Community development (CD),
started in the mid-fifties, is resurgent, but where such CD may be sponsored
by an extra-governmental organization, their efforts could wither on the vine
unless linked to higher levels; such linkage is often available only through the
governmental machinery.

Accountability and Public Administration


As the preceding discussion has shown, the discipline of PA has changed
over time both as a response to changing currents of thought within the social
science community as well as to the events in the country and the world which
press on both our understanding of the discipline and on its practice. In this
section, I shall try to locate each concept of accountability within the most
appropriate PA variety. In doing so, I want to show that these changes are not
merely analytical distinctions; rather they have been occasioned, like PA, by
developments in both the discipline and society.
Since types of PA and accountability have developed independently to
some degree, the congruence will not be total. Because of this, I shall not force
either to fit into any pre-conceived mold. As has been seen, both PA and ac-
countability have had four main varieties, each succeeding one building up on

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16V PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

and an improving its pedecessor in some way. Nevertheless, there is no


necessary supersession since aspects of the first continue up to the fourth
despite divergent relative emphases. However, the movement is not just an
expansion of the scope of each concept but a selection among the features and
their re-adjustment for coherence and balance.

TraditionalPA and the Accountability of Regularity


It is rather easy to see that the first type of accountability goes well with
traditional PA. Traditional accountability practically demands the doctrine of
the politics-administration dichotomy, where decisions are made outside the
bureaucracy and compliance is compelled all through the hierarchy but has its
ultimate arbiter in bodies external to the bureaucracy like the legislature and
the courts. Rules and procedures are set elsewhere and are rigid, thus re-
quiring the checks on performance on a line-by-line and strict pesos-and-
centavos accounting.

TraditionalPA, DevelopmentAdministrationand ManagerialAccountability

Despite its congruence with most of traditional accountability, the first


variety of PA has encouraged the start of managerial accountability through its
emphasis on the economy and efficiency of organizations.
This was carried over into DA. A number of management tools developed
under the DA period still tended to focus on inputs and the staff functions. As
already mentioned, most of the tools were developed in'the United States but
their applicability to a Third World country at the first stages of development
was hardly addressed. The techniques were regarded as capable of being useful
regardless of social conditions.

New PublicAdministrationandProgramAccountability
In a sense, New PA sounded the call for the stress on effectiveness of gov-
ernment activities while also underscoring the shift of development goals from
simple economic growth to more humanly appropriate objectives. The tech-
niques of program accountability fit the first thrust of New PA.
Comprehensive auditing is a major tool here but it was not a tool for program
accountability in the Philippines until the COA regarded it as one of its main
functions in 1975.14 Even comprehensive auditing, however, does not fully
encompass what New PA wants since it is still largely confined to internal
operations and does not evaluate agency performance in terms of its effect on
the community and the society.
A better suited technique is program evaluation, especially the analysis of
impact. This technique can also fulfill the New PA need for equity to the extent
that social impact especially on income distribution and poverty alleviation is

April
ADMINISTRATIVE ACCOUNTABILITY 131

made part of the framework. A number of government programs has been


subjected to various kinds of evaluation from the 1970's up to the present. Un-
fortunately, few managers have regarded these works from the perspective of
accountability and have not used them for the purpose of pinpointing re-
sponsibility for bottlenecks or failures and for improving program attainment.
The shortcoming may be blamed on both sides: on the evaluator or researcher
for his inability to disseminate his findings to the appropriate administrator
and to write actionable recommendations based on the findings; and on the
administrator for his tendency to shy away from critiques of his agency and
not pass up learning points from the criticisms.
New PA has stressed project management as an alternative to the rigid
bureaucracy. Under this strategy, a project may be packaged for a certain sum
for a given period of time and has a relatively flat organization which can be
created outside of an existing bureaucracy or from different organizations.
This type of project structure is expected to do better than regular organiza-
tions because of its intensiveness, circumscribed life, and relative freedom
from the rigidities of the mother organization. The project checks out its pro-
gram accountability at the evaluation stage of its life. Its effectiveness and
responsiveness could be increased
15
as it embraces a learning process rather
than a blueprint approach.

DevelopmentPA and ProcessAccountability


Process accountability has a lot in common with DPA. DPA features the
re-acceptance of the necessity of bureaucracy as long as it is reoriented to
include the participation of client and recipients in the process of administra-
tion, and the decentralization of decision making to local areas. Process ac-
countability has practically the same building blocks. Living with the bureau-
cracy, it seeks to involve both central and local units and their constituents
in the decisions for which the implementing units would then be responsible.
The standards are set at the bargaining table ,and are not some pre-conceived
set of indicators which are applied nationwide regardless of local conditions. In
effect, process accountability is a political rather than an administrative tool in
that responsibility sharing and even the definition of goals may emerge from
the negotiations.
There are not too many empirical examples of the use of process account-
ability. In the Philippines, a possibility is the Ministry of Local Government
(MLG) which has signified its willingness to experiment with a system of
classifying local governments according to their administrative capability for
development, determined jointly by the local units and the MLG. This will be
the basis for providing funds and technical assistance. The level of expected
performance will also depend on this joint assessment.
Process accountability is not applicable only to local governments. I can
envision, for instance, the Ministry of Health (MOH) evaluating its units using

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132 PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

this mode. Its recent reorganization operationalizes a number of features of


DPA. This includes the transformation of all central offices as staff units (an
old recommendation of the Integrated Reorganization Plan), the integration of
operations of hospitals and rural health units, and the hope for some kind of
bottom-up planning to take place. If the planning office can provide health
status information on all municipalities using for instance infant mortality and
size of population, then the central office has a rough index of the
administrative capability of local units (since health statistics is the result of
previous health administration) which can enlighten both sides when resource
needs are discussed. Meanwhile, each municipality may convene a participa-
tory council which will provide information on health-related resources as wel
as disease patterns particular to that local unit. With this information, the
locals have a fair idea what they need and the centrals the capacity of local
units. They can negotiate how many personnel, medical supplies and other
resources they require, how much they can support, what special technical
assistance they should get. Target setting can then be undertaken jointly
and funds-sharing also worked out. The central office can then demand per-
formance according to targets and withdraw or add resources during the year
depending on the local units' needs and level of effectiveness.
Stated in this way, it can be seen that process accountability is not such a
new concept since it is not a radical departure from previous procedures. What
is new is the participation of and negotiation by the units and the provision of
resources based on need, capability and promise, the last backed up by
recipient individuals. The requirement for each local area would differ
according to the results of the process, and therefore what one will ask from
each would be attainable. Each negotiating party can be held responsible for
the results and beneficiaries may even participate in the evaluation of per-
formance of the officials.

The Process of RegulatingBehavior


Accountability may be elicited both through the imposition of external
controls and through the inculcation of self-regulating values. In this section, I
shall deal with the first aspect which involves behavior regulation by,
outsiders. The next section will deal with the use of discretion by accountable
officials.
There are four major processes by which employee behavior may be
regulated. These are: control, supervision, influence and management. These
processes are often discussed in the literature in twos rather than altogether,
each pair highlighting a different dimension which would be useful in under-
standing regulation. In the section below, I will discuss the processes
according to the dimension by which a pair is distinguished, first applying that
categorization to the original pair and then locating the other processes in the
continuum so introduced.

April
ADMINISTRATIVE ACCOUNTABILITY 133

Source of Power
The source of power may be external to or internalized by the regulated.
External sources may be laws or bureaucratic rules which are imposed as
standards of conduct of subordinates. Disobedience to these rules may result
in sanctions by the controllers.
Control and influence are often contrasted in relation to the source of
power. For instance, Kernagham defines control as the "authority to command
and direct," implying that the compliance of the subordinate stems from the
hierarchical and legal authority behind the directive. He distinguishes "con-
trol" from "influence" which is "when B is molded by and conforms to the
behavior of A, but without the issuance of a command."'' 6 The implicit source
of influence seems to lie outside the bureaucracy, and may be rooted in one's
profession, ethical commitments and organizational affiliations.
Professional norms to the extent that they are imposed and enforced by
the bureaucracy may be regarded as an external source of power. However, if
compliance to them is mandated by extra-bureaucratic organizations, they
cannot be used as a means of control within the bureaucracy. They may still
regulate conduct however, if they are internalized and accepted as binding by
the officials concerned.

Kind of Rules Promulgatedby Regulator


A regulator may make the actual command which should be complied with,
or provide the regulated with options for action, through the issuance of
general guidelines on what action is expected or how a particular result may be
generated. Or instead of issuing rules, the regulator may depend on one's value
commitments (ethical, professional or similar rules) to get the desired result.
The kind of rules promulgated by the regulator seems to be the key distinc-
tion of the pair "control" versus "supervision," particularly in the local
government literature. Both processes are regarded as means of regulating the
actions of officials but are contrasted as regards the degree of autonomy al-
lowed them in carrying out their functions. As the judgment in Rodriguez vs.
Montinola puts it:
The Executive Power of general supervision over local government should not
be understood to mean or to include the right to direct action or even to control
actions. Such power however, may include correction of violations of law, or
of gross errors, abuse of office or mal-administration. In synthesis, the power
of general supervision granted the President, in the absence of any provision
of law, may not generally be interpreted to mean that he or his alter ego, a
Department Secretary (now Minister) may direct the form and manner in which
local officials should perform or comply with their duties.1 7
Control is then the more restrictive term, since it covers the form and manner
of performance of duties. Supervision is more open-ended, allowing officials
greater latitude in their actions. Director Gaudioso Sosmena, Jr. of the Bureau
of Local Government Supervision regards supervision as involving both regu-

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134 PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

latory and "assistory" dimensions. The former encompasses "the responsibility


to monitor local government compliance of national polices," as well as "the
formulation of the policy framework within which local authorities will be
allowed to administer their own affairs without losing relevance to established
national objectives. 8 The assistory aspect is the central effort towards
building local capacity. Although supervision is used here relative to local
autonomy, the concept can be applied to the relationship of any pair of agen-
cies where one sets general guidelines within which the other formulates its
rules of action. For instance, the Dean of the College of Law, UP is supposed to
supervise, though not control, the Law Center, a research unit attached to the
College.
If "influence" is now introduced to contrast it from both "control" and
"supervision" using this dimension, one immediately sees that the influence of
the regulator is predicated not so much on his commands and orders as on the
congruence of the commitments of his subordinates and himself. This con-
firms the notion above that influence is exerted through moral and other extra-
bureaucratic modes.

Assumed predictabilityof resultsof actions


Landau and Stout contrast "control" from "management", the first
proceeding from an assumption of a high degree of certainty, so that a
supervisor can prescribe action A knowing it will have result B. 19 In such a
case, a subordinate's action can be programmed and no discretion is allowed.
While a novel definition of control, this formulation does not depart from the
usual meanings attached to the term and is consistent with the concept of
"control" I had earlier discussed where the form and manner of compliance are
prescribed by authorities external to the regulated.
"Management" in Landau and Stout occurs when full knowledge and cer-
tainty are not assumed and a manager then treats each decision as a
hypothesis, the implementation of which should be treated as an experiment.
In this case, the manager accepts the possibility that he could be wrong and
thus be more receptive to other ideas of how to reach a certain goal. The basis
of management rests to a large degree on an external authority; but since the
regulator lays himself open to options coming from his subordinates, his
authority over them is likely to be enhance by resort to non-bureaucratic
standards and values. The rules he promulgates are not directives or even
guidelines about expected result as much as how these results may be
generated. In short, he will probably give process rules.
While Landau and Stout did not deal with influence, one can extend their
notion of "control" and see "influence" as used when a manager has great
trust in his belief (although probably not fully certain) that a certain course of
action will produce a particular result. Therefore, he will mold his subordinates
to see things the way he does. "Control" and "influence" then does not differ
in the proposition they make about cause and effect, only in the starting point

April
ADMINISTRATIVE ACCOUNTABILITY ijo

of the managers' mind and his possible openness to extra-bureaucratic


standards.
Landau and Stouts "management" is similar to "supervision" in that the
latter as the regulator provides autonomy and opens himself to the possibility
that a guideline may be followed in diverse ways-in different jurisdictions.
However, "supervision" appears to be more restrictive than ',management" in
the regulatory dimension, and as wide-ranging as "management" as it enhance
the capacity of the regulated.
As have been seen, discussion of each pair uses a different dimension of the
regulatory power to contrast one concept from the other. An attempt to
extend each discussion to deal with all four processes is shown in Figure 2.

Figure 2. Processes used for Regulating Bureaucratic Behavior

Control Supervision Influence Management

Source of External to External to Internalized Both external


power the regula- the regulated by regulated and intern-
ted alized
Kind of Direct General Moral, Process rules
rules commands, Guidelines ethical and
programmed other extra-
decisions bureaucratic
standards
Assumed High Low High Low
predictability
of results
of decisions

Accountability and Types of BureaucraticPower


In comparing the kinds of accountability, it is interesting to note that each
stresses a different set of powers for the evaluating official. Traditional ac-
countability with its emphasis on regularity and compliance relies on control,
or the authority to command and direct, in bringing about responsible be-
havior. The hierarchical superior in the agency as well as the President, the
legislature and the courts provide the officials little discretion; their power is
thus strengthened by rules, the violation of which carry heavy penalties. In
having to account for detailed use of inputs, officials sometimes protect them-
selves by making sure they commit no violations. Moreover, there is little
encouragement of initiative and innovative performance.

Managerial accountability uses a combination of control and supervision.


In its concern for avoiding waste and increasing efficiency, it may restrict the
way funds and resources are utilized and systems may reign supreme without

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regard to their effects on programs or the administrator may allow his lower-
ranking units leeway in the use of resources as long as general guidelines are
observed, paving the way to an emphasis on supervision.
By contrast, program accountability with its focus on results must use not
so much control and supervision as influence and management. However, a
minimum compliance with control measures may be required.
Beyond the minimum compliance, autonomy of the implementing officials
may be the rule, especially for innovative programs where results are hardly
predictable. Since programs must meet professional standards as well as one's
conscience, a manager cannot exact program accountability simply by check-
ing if laws have been followed. Rather he must find out if goals have been
attained. Since several standards-bureaucratic, technical, moral-can be used
in this evaluation, the manager must convince his employees that his defini-
tion of the situation is preferable and should prevail. Their acceptance results
from persuasion and education, it cannot be legislated.
The power prevailing in process accountability is a combination of
supervision and management. I would stress the last, since process account-
ability focuses on the results of the negotiations and bargaining of both
regulator and regulated. Thus, the regulator must indeed take each action as a
hypothesis, with certainty ruled out, and allow the regulated some discretion in
his approach to the program. This would mean an accountability that would
face up to errors and even embrace them as learning points for later growth. In
this case, control and influence which are predicated on the accuracy of the
regulators' diagnosis of the situation will not occupy center stage.

Discretion and Accountability


The preceding discussion shows that the concept of accountability and
Public Administration thoght have evolved into more modern and open-ended
varieties. The trend has moved away from legalism and item-by-item control
into concerns with program content and participatory processes. The citizen
can now expect that his demand from government will not be forcibly fitted
into a routine that does not embody its major aspects. Rather, it will be
considered in its full complexity and be provided a decision answering his
peculiar needs. Modern accountability can thus lead to more effective and
responsive behavior.
However, the use of the image of evolution is apt. Process accountability
and DPA are not totally new formulations which are borne out of a complete
break with the past. Although traditional standards may not receive as much
emphasis as before, they continue to be bases for judgment of the acceptability
of an official or employee's behavior. While legality is overshadowed by effec-
tiveness, regularity and compliance continue to be exacted of civil servants
who are also expected to deliver programs in an adequate and responsive
manner.

April
ADMINISTRATIVE ACCOUNTABILITY

The juxtaposition of several standards on the evaluation of the same act


would lead to conflicts within the bureaucrat himself or between him and his
controller. Some of these conflicts may arise from differences between profes-
sional and bureaucratic criteria, or more broadly, the divergence between moral
and legal decisions. A further twist is introduced when extra-bureaucratic
norms lead to behavior which is viewed as irresponsible by the controllers.
I shall explore each of these value-conflicts in turn.

BureaucraticVersus ProfessionalNorms
As one stresses programs, it may be inevitable that technical criteria
rather than those of the traditional accountant and auditor and of bureaucratic
procedures be utilized to a greater extent. This shift may cause conflicts within
the bureaucracy since the technical standards of the profession most relevant
to the program may not completely coincide with or support all the standards
promulgated by the bureaucracy. In theory, the conflict cannot occur since
bureaucratic procedures are supposed to be dependent on the same technical
criteria that guide the performance of the experts within the agency. Such pro-
cedures are based on regular transactions and on the usual issues that an
official may be expected to meet in the normal course of his duties. When well-
formulated, they may suffice for routine cases which require little or no
decision by the bureaucrat. In the computer age, these routine cases are
normally the kinds of cases which are machine-programmed, the computer
being uninfluenced by specific character traits of a client which the rules do not
recognize as material and relevant.
However. the treatment of exceptional circumstances cannot be program-
med. Where the procedure recognizes such cases as exempt from the routine,
few problems arise, since the rules would generally provide for the exercise of a
discretionary rather than a ministerial function. Where that exception is not
allowed for, or when bureaucratic rules are deficient in dealing with special
cases, or when rules become ends in themselves, the bureaucrat may be forced
to choose between the criteria of his agency or that of his profession. For
instance, a social worker may feel compelled by her professionalism to devote
long and intensive periods of time in counselling a person in need, but this ac-
tion may not sit well in an agency with rules on punctuality and eight-hour
days as well as targets as to how many persons have to be served per week.
The profession-bureaucracy conflict is involved but it is only one of several
possible conflicts when there is more than one standard of accomplishment,
and therefore of accountability. It reopens for us the debate in the 1940s
between Herman Finer and Carl Friedrich who each had argued that his
particular brand of responsibility should be the basis for evaluating bureau-
cratic performance. Finer can be regarde& as an exponent of traditional ac-
countability as he identified the essence of accountability as "to whom and for
what one is responsible," this paramater being fully encompassed by law and
organization chart. Meanwhile, Friedrich wants responsibility to be elicited

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138 PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

rather than enforced and its essence captured by the phrase "to whom and for
whom one feels responsible and behaves responsibly. "20 Finer does not deny
that a sense of responsibility is very important in keeping an agency or an
official efficient. However, he maintains that accountability must be defined as
the degree of effective answerability which in a democratic government is as-
certained "not by officials who decide their own course, but by the elected
representatives of the public... (who) determine the course of action of public
servants to the most minute degree that is technically feasible. "21
On the other hand, Friedrich enshrines professional norms as well as in-
dividual conscience as appropriate judges of a person or agency's performance.
Thus, a person may choose to disobey the rules of the bureaucracy and still
pass the test of accountability if he can show that the goals of the agency are
better served thereby. An actual case that illustratesthis resolution concerns a
regional director of an agency involved in land reform who was purged from
office in 1975. The basis of the summary action was a pending administrative
charge which contended that he violated rules regarding attendance and prac-
tice of his profession during office hours. He in fact did not take the precaution
of getting an exemption from the latter regulation. At the time under ques-
tion, he had appeared in court to defend a group of tenants in a suit against
their landlord, an action which he considered as furthering his agency's objec-
tives. When the case was re-investigated, the official was reinstated and re-
ceived, in addition, a commendation from the then Department of Agrarian
Reform (DAR) for his act of conscience.
Legal andMoralDecisions
Why do problems like this arise in a bureaucracy? The contrast Foster
makes between legal and moral decisions may be instructive:
Moral decisions are value-based decisions that are content-and context-speci.
fic; legal decisions are just the opposite: procedure-based decisions that are
dependent upon historical precedent. Generally, a law is born as a response to a
peculiar (atypical) behavior that exceeds the bounds of social acceptability,
even where those bounds might not be representative of the society as a whole.
Thus, the specific exception gives rise to the general rule, which thereafter
provides the basis for countering comparable exceptions. This process of cod-
ification and standardization serves to define situations that the moralist
would view as unique according to some generic structure. The ultimate effect
is to reduce environmental uncertainty, to narow the gauge of interpretation,
by delimiting the number of unique situations possible. 22
Legalism then makes it possible to deal with a huge number of cases and
seems to promise accountability by its capacity to limit arbitrary behavior.
However, legalism may be carried to the extreme, routinizing even situations
which provide reasoned exceptions. Gawthrop suggests that this fosters an
"ethics of civility.... that ethic which insures that public administrators will
not do the things that should not be done."2' 9 The ethic encompasses
mechanical adherence to the letter of the law and was encouraged by Woodrow
Wilson (according to Gawthrop) because at that time democratic government

April
ADMINISTRATIVE ACCOUNTABILITY 139

was not under threat. Its "vacuousness became obvious at Watergate when
the overwhelming majority of civil servants did nothing they should not have
done, given the ethical framework." 24 Negative thinking may keep people out
of jail but it does not provide service. The emphasis tends to be on the search
for non-compliance, malfeasance and culpability rather than on positive activ-
ities. In an effort to be regular and legal, bureaucrats may instead become
legalistic, stressing formal compliance with the letter of the law. That in turn
may lead to goal displacement where rules become the master while
bureaucrats are reduced to timidity, conservatism and technicism.''25 Too
much legalism may even become a major factor inhibiting the move towards
26
development
"New PA" brought values out of the closet and legitimized their role not
only in the practice of public administration but also in its theory. The con-
sciences of scholars and officials have been developed before New PA of
course, but New PA forthrightly enshrined the spirit of the law and not its
mere compliance. Carl Friedrich discoursed on subjective responsibility long
before New PA advocates earned their master's degrees but his advocacy of it
fits in with their concerns. An accountabilkity more grounded in morality than
legislative fiat requires techniques that probe not only whether it can be
proven that the bureaucrat did not do a proscribed act, but more importantly,
whether or not he tried to do as much as what is in his power to do according to
his best understanding of the public interest. It is a positive pro-action rather
than an ability to dodge punishment.
I have stated above that the traditional forms of accountability may be
criticized for overemphasizing legality. Yet if one would be responsible, the
rule of law must continue to be upheld. In this connection, Foster suggests
"intermediate legalism ' 2 7 -laws as if people mattered, that complements and
actually fosters moral behavior by developing the willingness to make difficult
moral decisions.The emerging "ethics of consciousness" 28 enhances the attain-
ment of goals and thus the use of responsible initiative and flexibility.
ExtraBureaucraticStandardsand IrresponsibleBehavior
There would be fewer problems if the entrance of extra-bureaucratic values
into agency decision making were always an unmixed blessing. In many cases
however, this result does not obtain. An example would be putting the family
above all others, manifested in such acts as nepotism or giving of choice
licenses to relatives. Cultural values such as pakisisama, utang na loob and
regionalism may also lead to decisions which are grossly unfair to people who
are not beneficiaries of the particularistic allocations. These problems are quite
formidable in the Philippines. There are writers who suggest, in fact, that a
concept like graft and corruption may be alien to a culture like the Philippines,
which is gift-giving, personalistic, and particularistic. 2 Although there are
indeed values in the culture which appear to promote the commission of graft,
there are nevertheless other values such as fair play and honesty which are
endemic in the culture and which, moreover, are factors that could prevent or

1983
140 PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

at least negatively evaluate corruption and other activities that would give
preferences unfairly20 Values are in fact not positive or negative determinants
of responsibility per se. Utang na loob may make an official work responsibly
in the bureaucracy if in his desire to pay off a debt of gratitude to his super-
visor he works harder at his job to please him. A person who owes a debt of
gratitude to another may also repay him in areas outside the bureaucratic
realm. It is in fact not really expected by the culture that an official will
discharge his utang na loob by using government funds and resources. There-
fore, if an official can become more responsible in discharging his official duties
because he is imbued with utang na loob or if another official will become more
corrupt because he is forced to do so by the same utang na loob, it is clear that
the intrusion of values is not the culprit in the commission of irresponsible be-
havior. Moreover, the College of Public Administration (CPA-UP) study of
graft and corruption suggests that the clash of cultural norms and Weberian
rules or what we have called "favor corruption" is not the major source of the
problem. Rather, most of the corruption are market-type transactions where
greed for money and power is the primordial force. The favoritism towards
cronies is indeed at work, but pakikisama alone would not have propelled it
very far if no illicit monetary rewards were available for the sharing by the
3
privileged friends on both sides of the bureaucratic exchange. '
It is therefore incumbent upon us to recognize and evaluate how the values
that motivate people are manifested in the bureaucracy. Of course, the old
strategy for avoiding value conflict and the possible problems brought by the
intrusion of extra bureaucratic values into the bureaucracy have been simply
to make bureaucrats' area of decision as narrow as possible. As my discussion
of accountability and public administration has shown, both thought and
practice have tended to move away from this straight-jacketing. However,
with all these problems and the possibility of value conflict which the bureau-
crat may find difficult to resolve, why then should I continue to press for more
discretion by the bureaucrats? There are several answers to this question: (1)
the nature of the human being (2) the complexity of present day society, and
(3) the inefficacy of the legalistic approach.
(1) The Nature of the human being. Since the time of Chris Argyris and the
Hawthorne experiments, it has been recognized that a person is a human being
rather than a machine. These experiments showed that men are decision
makers even in areas where they are supposed to have no discretion. In an
earlier study of graft and corruption, I have found that people deviated from
procedure for corruption purposes even if the function under question was
ministerial rather than discretionary. 2 This shows that people win choose
even if the rules do not allow them to do so. Rules may circumscribe their
choices to the extent that the pressure of other values is not stronger For
instance, generally a bureaucrat may obey the rules of his office and follow
standard operating procedures. But when a person he wants to please is not
qualified to receive a service, he may disregard these rules or go around them
in order to suit this person. The problem appears to be not so much a question

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ADMINISTRATIVE ACCOUNTABILITY 141

of limiting choice behavior, as of a question of increasing the chances that an


official would make decisions based on factors rational to the bureaucracy.
(2) The Complexity of Society. Perhaps, it is no accident that both Public Ad-
ministration and accountability have evolved towards more discretion. So-
ciety today is far more complex than it ever was-at the same time that
government itself has enlarged and intervened from the cradle to the grave.
Specifically, the Philippines which has been called the fusion of the East and
West3 maintains part of its endogenous culture in the midst of American
standards propagated by mass media and schools. Its economy ranges from
the carabao-pulled plow to space-age assembly lines (many of which are
however like industrial revolution sweatshops). In one area, an official may
meet a docile community which he cannot rouse from its lethargy. A few
kilometers onwards, he may encounter a beehive of protest which he cannot
still. It is not yet the "turbulent society" the American New Public Admin-
istrationists describe but it is rapidly changing and is no longer a homogeneous
mass. Thus, demands and pressures on government canot be easily trans-
formed to standard operating procedures which break no exceptions.
Under this condition, it is not possible for rules to anticipate and categorize
every important set of situations.
(3) Inefficacy of the Legalistic Approach. A third answer leads to the
empirical record: the enactment of one of the strictest set of laws on record has
not been able to hold down the incidence of graft and corruption, a major
object of national shame identified in survey after survey.34 The behaviors sanc-
tioned are comprehensive. In fact, an official is enjoined not to be clean but
also to appear clean.35 The instruments for catching crooks are also impres-
sive. They include the usual legal evidence plus a regularly filed statement of
assets and liabilities designed to ferret out sudden wealth. The penalties are
also expected to be high enough to discourage wrongdoing. Moreover, a set of
investigative agencies has been created in sequence since the 1950s, the
latest of which include three constitutional bodies, the Sandiganbayan, the
Tanodbayan and the COA. Unfortunately, the records on recovery of funds
illegally used or taken from government agencies and the prosecution of the
wrongdoers are both poor. In 1981, the Annual Report of the COA showed
that only about three percent of all proceeds from graft or corruption for the
year was ever returned.96 Similarly, court cases against government swindlers
and other forms of corruption have rarely flourished. First, few qualified
opinions of the COA-suggesting a possible deviance-are ever followed up by
the agencies or the Solicitor General through administrative charges or court
cases against the suspects. Even when suits are lodged, few ever flourish. The
Sandiganbayanreports that from 1980-1982, most of the cases are disposed by
"archiving without prejudice" that is, the accused canot be brought to trial be-
cause he has not been caught. Meanwhile only eleven (11) percent of
government funds has been recovered2 7 Besides, cases that have progressed
involved so-called "small fry" rather than prominent officials suspected by
public opinion as corruptors. This recalls Climaco's report, as Chairman of the

1983
142 PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

Presidential Anti-Graft Commission (PAGCOM), that after a year in office, his


accomplishments can be characterized as "no hits, no runs, all expenses, no
convictions.' '38
The inefficiency of the law seems to stem from three main problems: (a)the
systenc nature of corruption; (b) the formalism in the laws, and (c) the lack of
political will.
a. Systemic nature of corruption. Studies of the CPA have shown that a
large number of negative bureaucratic behaviors is committed by officials and
employees with the tolerance if not the outright encouragement of powerful
members of the bureaucracy. The "syndicate" includes persons throughout the
agency and their activities are parallel to the standard operating rules and
procedures they flaunt. They leave precious little evidence, for the language of
corruption is easily learned by and passed on to both employees and clients
who can profit from its use. Increasing safeguards against these nefarious
activities tend to increase only the number of those who could be involved.
As President Marcos himself stated in 1975, referring to a major
watchdog agency:
The conclusion is ineluctable that in a great number of cases, graft and corrupt-
ion in the government has been possible only with the collusion, participa-
tion, if not the instance of personnel of the Commission on Audit. This is one
of the offices in the government which has to be completely reorganized.'39
The COA has since withdrawn one of its controversial control points,
the pre-audit. But the classical query remains: who will guard the guardians?
b. The formalism of the laws. A society has formalistic laws when they are
not expected to be fully implemented, only to serve a window-dressing role.
More perniciously, they may be implemented whenever convenient, i.e.,
against enemies of the regime, against poor folk, against anyone at particular
times. The laws to regulate administrative behavior in the Philippines have
from time to time been accused of being formalistic. For instance, they catch
small fry and let the big ones go. Or in periodic ningas-kugon outbursts, viola-
tors at that time are caught while the rest who know their timing are un-
punished. The purges at the height of the martial law period also exhibited this
"whimsical" character, as it labelled as notoriously undesirable otherwise
incorrupt men who have long been dead, resigned or transferred, while retain-
ing better known wrongdoers, particularly those with connections. Formalistic
law is unpredictable and unfair and is not a good guide for regulating behavior.

c. The Lack of political wilL Law would be more effective if the people in
and out of the bureaucracy perceive that they will be implemented vigorously
and fairly. Case studies of individual agencies have shown that integrity and
rectitude-or at least, less corruption-obtains when the head of an agency
forthrightly declares himself against corruption and follows up his avowal
with the strength of his example and actions. ° They suggest that if the

April
ADMINISTRATIVE ACCOUNTABILITY

highest leadership has the will for clearing up the bureaucracy, it can serve not
only as a role model but also as a rallying point for better accountability of the
entire civil service. Leadership here of course refers not only to one person but
to the whole group of power wielders. Their self-interest may be towards the
perpetuation of their power which may not coincide with fairness and justice to
the people. In the end then, laws may be ineffective because it is not convenient
for the purposes of those in power.

Towards Increasing Accountability


Several nagging questions remain: if officials are no longer expected to
comply with direct orders, how can they be regulated? And: won't too much
discretion result in even mere inefficiency and corruption? How can the
people's will be followed if bureaucrats are allowed to "do their own thing"? In
the COA, many auditors wore blackbands when pre-audit was lifted as a
protest against the COA's loss of control over managerial decisions that for
them augured badly for the future of accountability in government. 41 The prem-
ise of the protest can be easily dismantled: the COA as an independent
agency should not participate in the decision making of the very offices whose
transactions they will later audit. Moreover, the withdrawal confirmed the
COA's firm belief that accountability should be fully in the hands of the
manager. But the concern cannot be silenced by that simple definition of
territory. For the move simply removed one safeguard against wrongdoing
without substituting a new and a stronger deterrent. (It, instead, went into the
3E's and performance auditing which are seen as after-the-fact methods rather
than preventive procedures.) The question raised is: if any illegalities or ineffi-
ciencies are then unearthed, what punitive measures can be levied against their
perpetrators so that future violations would not take place? Many officials and
citizens feel that tighter control is needed and regulation through management
and influence should be curtailed. They fear that "modern" notions of account-
ability which stress negotiation and even self-determination of standards
rather than compliance will result in even worse performance by an even
greater number of employees and administrators. How then can administra-
tive accountability be obtained?
The questions are serious and difficult but if my reading of DPA is correct,
it is already exploring the possible answers. These answers would constitute a
multi-pronged response which will touch the bureaucrats before and while they
are in service, the clientele and the society from which they come, and the
regulators within the civil service and the external bodies which control,
supervise or influence it. These bodies will be secondary regulators, in the
sense that they will be assistive, with primary responsibility falling upon the
administrator who will set the standards (preferably in consultation with staff
and clients) and evaluate performance accordingly. The standards to be used
will also be diverse, but will attempt to get effectiveness and participation
along with compliance and lower costs. It is expected however that the tilt will

1983
144 PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

be towards the spirit of the law and the program content rather than a literal
interpretation, should conflicts between these values arise.
'For the civil service, then, some kind of bureaucratic reorientation would
be required. If personnel and offices are judged in terms of their programs,
measurement techniques may prove to be less valuable than socialization pro-
cesses. This is where training, not so much of skills, as of attributes and com-
mitment can prove necessary. Approaches like barangay immersion, 2 various
styles of sensitivity training, and Organizational Development (OD) become
not just attitude-modifying mechanisms but themselves instruments for en-
hancing accountability. In fact, one may view the contrast between fiscal and
managerial accountability and program and process accountability using the
analogy of medicine, where the former are curative tools for dealing with the
patient after sickness has struck (or errors have been made) while the latter are
preventive, seeking to steel the patient against possible injury by strengthen-
ing his moral fiber prior to any temptation.
Indeed, such training should be in the content of curricula prior to the
entry of people into the bureaucracy. Therefore, extra-bureaucratic institutions
like the home, the church and the school share equal responsibility in instilling
a sense of responsibility, service and nationalism that accountable officials
should manifest.
The growth of professionalism would be positive for accountability. Train-
ing for a profession and other specialized occupations involves knowledge and
skills as well as attitudes, and the code of ethics each teaches and follows pro-
vides guidance even for those in the bureaucracy.The possibility of conflicts
between professional norms and the bureaucracy will not be erased but it may
be risked since the context-specific application of norms would be valuable in
any setting.
In institutions teaching Public Administration, the question of a special
course on Ethics looms time and again. I think what is required is a clarifica-
tion of the goals of the nation and the requisite commitments of bureaucrats
that will operationalize and achieve them for and with the people. This entails
thinking on equity, justice and the general welfare. If learned in this context,
training in the act of making decisions for which one takes responsibility may
not be consciously taught apart from the skills themselves, but it may be as
effective as a separate course on ethics. Indeed, what is called for is the
permeation of ethics in the curriculum because the code 43of conduct is better
learned in context than as an imposed floating set of rules.
This is consistent with DPA's espousal of bureaucratic reorientation
which is not mere attitudinal modification. It involves changing the regula-
tors by making them less controllers than managers, and encouraging them to
set up performance standards negotiated with the staff and the people they
serve. The process of management and supervision will then be more develop-
mental and assistory than regulatory, and will be set realistically with the

April
ADMINISTRATIVE ACCOUNTABILITY 145

capacity and potential of bureaucrats and agencies in the specific geographical


and functional areas they serve well in view. Having done this, punishment
should fall on those who violate agreements.
Development PA does not do away with rules. Following Barnard, they
are accepted, not simply promulgated on unwilling subjects. As rules and
standards are accepted, the regulators would perhaps move towards less for-
malism and more sincerity. The predictability of the behavior of regulators
is an influential guide to the behavior of their employees. At the same time,
regulators who enforce rules in the same way regularly gain reputations for
fairness from both their staff and clientele-producing a climate under which
corruption will not thrive. These changes on the regulator and the staff will not
come by as religious conversion, although a greater sense of commitment and
morality will help. It needs to be backed up by support and resources. Else-
where I have called for the increase
44
of salaries as a humanitarian gesture, not
just as an anti-corruption device.
For the outside regulatory agencies, the withdrawal of both COA and the
CSC from direct decisions on internal matters is a step in the right direction
and signifies again the primacy of the responsibility of the agency administra-
tors for their own programs. However, since they as well as the Tanodbayan
and Sandiganbayanexist as central agencies watching over line ministries, the
kind of decisions they make and their follow-through can also set the tone for
the type of accountability that is in fact exacted. Both the COA and the CSC at
present can point out irresponsible behavior. The COA has the edge in that
through its audits, it can initiate inquiry into possible irregularities while the
CSC has tended to wait for cases to be brought before it. (Here, it is like the
Sandiganbayan.)But both the COA and the CSC lack teeth and cannot enforce
their decisions in specific cases, although they can promulgate rules that could
prevent the occurrence of similar injustices or inefficiencies in the future.
However, as Foster implies, making a rule for what may be an exceptional sit-
uation could hamstring the effectiveness of managers.45 Such clout may be
provided only to show which behaviors are sanctioned or encouraged, and
under what conditions. At the very least, more information on their guiding
norms and current decisions would provide the bureaucrats the ground rules
for their own acts.
For the Tanodbayan, I endorse heartily Alfiler's recommendation 46 for a
pro-active role similar to the strategy of the Hongkong Independent Commis-
sion against Corruption (ICAC). The ICAC has a strong corruption prevention
unit which assists agencies in educating the public on the latter's functions.
More importantly, it undertakes "assignment studies" which analyze the
causes, nature and processes of corruption in specific agencies so that
opportunities for deviancy can be recognized and removed. Where corruption
persists after this close analysis, alleged wrongdoers are brought to court for
possible punishment to the full extent of the law.4 7 The twin strengths in pre-
vention and sanctions help to define in particular context what the laws want.
Since the Tanodbayan has a broader scope than anti-corruption, its special

1983
14b PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

studies may extend to such areas as inefficiency, unfairness or poor public


service.
The President and legislature are expected to do their share in prevention
and punishment. The BatasangPambansa should take up its investigatory
function as vigorously as the old Congress did to keep administrators on their
toes. Both sets of lawmakers (the President having this power still) should also
reexamine whose interests its policies serve, since unfairness and corruption at
super-bureaucratic levels are convenient alibis for erring civil servants and
terrible causes for the erosion of public confidence. The fairness and even-
handedness of these agencies must be expected and realized.
The involvement of the citizens in programs should also be fostered. More
than just beneficiaries, they may participate even in setting the standards
under which officials and employees will be judged. This can be done more
practically in local communities, and suggests a bottom-up approach to the
administrator. A constant dialogue with the public serves to make the agency
more aware of points of pride as well as of criticism. In addition, the people
affected will need more than a pious avowal of their sovereignty. The predict-
ability and commitment of the administrators, the regularity in the enforce-
ment of rules, the punishment of all wrongdoers and the evidence of a political
leadership that fears the wrath of the people are indispensable for keeping civil
servants ever aware of their accountability to the people.

ENDNOTES
1
Following Waldo, I will capitalize Public Administration when referring to the discipline, and
limit the lower case to its practice.
2
Charles S. Hyneman, Bureaucracyin a Democracy (New York: Harper and Brothers Publish-
ers, 1950). See also Frederick Mosher, Democracy and the Public Service (New York: Oxford Uni-
versity Press, 1968).
3
Richard Brown and Ralph Craft, "Auditing and Public Administration: The Unrealized Part-
nership," PublicAdministrationReview, Vol. XLI, No. 3 (May-June 1980), p. 259.
4
My context is specific to developing country like the Philippines whose understanding of the
concept of development and hence, of its goals has also grown over time.
5
Gregory Foster, "Law, Morality, and the Public Servant," Public Administration Review,
VoL XLI, No. 1 (January-February 1981), p. 30.
6
Jerome B. McKinney, "Process Accountability and The Creative Use of Inter-Governmental
Resources," PublicAdministrationReview, Vol. XLI, No. 1 (January-February 1981), p. 144.
7
Francisco S. Tantuico, Jr., State Audit Code of the Philippines(Quezon City: Commission on
Audit Research and Development Foundation, Inc., 1982), p. 8.
8
Leo Herbert, "A Conceptual Framework for Understanding Auditing," prepared for the TCD/
Development Administration Division, United Nations, Commission on Audit Journal VoL XXXI
(December 1982), p. 17.
9
Tantuico, op. cit, p. 12.
10E. Leslie Normanton, "Reform in the Field of Public Accountability and Audit: A Progress
Report," State Audit Developments in Public Accountability, ed. B. Geist (Israel: State Comp-
troller's Office, 1981), p. 34.
11
McKinney, op. cit., p. 145.

April
ADMINISTRATIVE ACCOUNTABILITY 144

12
0.P. Dwivedi, "Accountability of Public Servants: Recent Developments in Canada," In-
dianJoumalofPublicAdministration, VoL XXVI, No. 3 (July-September 1980), pp. 761-765.
13 Luzviminda G, Tancangoo and Salahuddin Md. Aminuzzaman, "Theory and Practice of
Public Administration: A Review of the State of the Art," a paper presented in the second Na-
tional Conference on Public Administration held at the Philippine International Convention Cen-
ter, Manila on Nov. 3-Dec. 1, 1982.
14
The 1973 Philippine Constitution,Art. XII-D, Sec. 2, para. 3 gives the COA the power to
recommend measures necessary to improve their (referring to the Government and its Agencies)
efficiency and effectiveness.
15
David C. Korten, "Community Organization and Rural Development: A Learning Process
Approach," Public Administration Review, VoL XLI, No. 5 (September-October 1980). pp. 480-
511.
16
Kenneth Kernaghan, "Responsible Public Bureaucracy: A Rationale and a Framework
for Analysis," CanadianPublicAdministration,Vol.XVI, No. 4 (Winter, 1973), pp. 581-584.
17Rodriguez v. Montinola, 94 Phil. 972.
18
Gaudioso Sosmena, Jr., "An Emerging Concept of Local Government Supervision," 1982,
p. 9. Mimeo.
19
Martin Landau and Russel Stout, Jr., "To Manage is not to Control Or the Folly of Type
II Error," PublicAdministrationReview, VoL XXXIX, No. 2 (March-April 1979), pp. 148-155.
20
Kernaghan, op. cit, pp. 580-582.
21
Hern Finer, "Administrative Responsibility in Democratic Government," Public Ad-
ministrationReview, VoL 1, No. 4 (Summer, 1981), p. 336.
22
Gregory Foster, "Law, Morality and the Public Servant," Public AdministrationReview,
Vol. XLI, No. 1 (January-February 1981), p. 31.
23
Louis C. Gawthrop, "Administrative Responsibility: Public Policy and Wilsonian Legacy,"
Policy Studies Journa4 Vol.V, No. 1 (Autumn, 1976), p. 110.
24
1bid, p. 109.
25
Robert K. Merton, Alsa P. Gray, Barbara Hockey, and Hanan C. Sevin, A Readerin Bureau-
cracy (New York: American Book Stratford Press, Inc., 1952).
26Lucian Pye, Aspects of PoliticalDevelopment(Boston: Little Brown, 1966).
27
Foster, op. cit, p. 33.
28
Gawthrop, op. cit., pp. 111-113.
29
0.D. Corpuz, "The Cultural Foundations of Filipino Politics," PhilippineJournalof Public
Administration,VoL IV, No. 4 (October 1960), pp. 297-310.
30Ilivina V. Cariflo, "The Definition of Graft and Corruption and the Conflict of Ethics and
Law'"PhiippineJournal of PublicAdministration,Vol.XXIII, Nos. 3 and 4, (July-October 1979),
pp. 221-240.
31Ldivina V. Cariio and Raul P. de Guzman, "Negative Bureaucratic Behavior in the Philip-
pines: The Final Report of the IDRC Philippine Team," PhilippineJournalof Public Administra-
tion, VoL XXIII, Nos. 3 and 4 (July-October 1979), pp. 350-385.
32
Ledivina V. Carifio, "Bureaucratic Norms, Corruption and Development," PhilippineJour-
nalofPublicAdministratio, VoL, XIX, No. 4, (October 1975), pp. 278-292.
33
Ferrel Heady, "The Philippine Administrative System-A Fusion of East and West," Phil-
ippineJoumalofPublicAdministration, Vol. 1, No.1 (January 1957).
34
Jose Abueva, "The Contributions of Nepotism, Spoils and Graft to Political Development,"
PoliticalCorruption, ed. Arnold J. Heidenheimer (New York: Holt Rinehart and Winston, 1970).;
Harvey Averch, John E. Kochler, and Frank H. Denton, The Matrix of Policy in the Philippines
(Rand Corporation: Princeton University Press, 1971).; Wilfredo A. Clemente II and Constanza
Fernandez, "Philippine Corruption at the Local Level," Solidarity, Vol. VII, No. 6 (June 1972);
Felipe B. Miranda, "Metro Manila Survey on Government and Politics: Identification and
Analysis of Potential Sources of Political Stress," A FinalReport on the Social Weather Station
Project (Metro Manila: Research for Development Department, Development Academy of the
Philippines, 1981).

1983
148 PHILIPPINE JOURNAL OF PUBLIC ADMINISTRATION

35
Cariffo, "The Definition .......... op. cit
36
Republic of the Philippines, Commission on Audit, Annual Report, 1981.
37
Ma. Concepcion P. Alfiler, "Corruption Control Measures in the Philippines: 1979-1982" for
the President's Center for Special Studies, March 1983. Mimeo.
38
Carifo and de Guzman, "Negative op. cit., p. 364.
".........

39
Speech delivered by President Ferdinand E. Marcos at the Luneta Grandstand, Manila on
September 19, 1975.
40See "Special Issue: Graft and Corruption," Philippine Journal of Public Administration,
Vol. XXIII, Nos. 3 and 4 (July-October 1979), pp. 221-385. See also Jose N. Endriga, "The Com-
mission on Audit: A Case Study of Administrative REform," a paper presented in a public lecture
on August, 1981 at SAAC Auditorium in connection with the UPCPA-COA Professorial Chair.
The same paper is published in the Commission on Audit Journal,Vol. XXX (September 1982), pp.
2-27.
41
At least one official has implied that the protest was not necessarily noble-they mourned
for more personal reasons than the decrease of safeguards for accountability.
42
1ud.ina V. Cariffo and Ema B. Vifieza, The Indang Experience: Lessons from the First
Career Executive Service Development Program Barrio Immersion (Metro Manila: Academy
Press, Development Academy of the Philippines, 1980). See also "Barrio Immersion" Issue, Phil-
ippine JournalofPublicAdministration,Vol. XXIV, No. 4 (October 1980).
43
0.P. Dwivedi, "Curriculum Development for Ethics, Responsibility and Accountability in
the Public Service," presented in the meeting of the International Association of Schools and
Institutes of Administration (IASIA) Working Group on Ethics, Responsibility and Accountabi-
lity in the Public Service, 1982.
44Cariffo and de Guzman, "Negative .......... op. cit.
45
Foster, op. cit
46
Alfiler, "Corruption Control ........ op. cit.
47
Jeremiah K.H. Wong, "The ICAC and its Anti-Corruption Measures," Corruptionand Its
Control in Hongkong, ed. Rance P.L. Lee (Hongkon- The Chinese University Press, 1981), pp.
46-72.

April

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