Dishonesty as administrative offense
In a long line of cases,
dishonesty has been defined as the
disposition to lie, cheat, deceive or defraud; untrustworthiness; lack of
integrity; lack of honesty, probity or integrity in principle; lack of fairness
and straightforwardness; disposition to defraud, deceive or
betray.[1] Although dishonesty covers a broad spectrum of conduct,
Civil Service Commission (CSC) Resolution No. 06-0538[2] set the criteria for determining the severity of dishonest acts.
CSC
Resolution No. 06-0538 recognizes that dishonesty is a
grave offense generally punishable by
dismissal from service.[3] Nonetheless, some acts of dishonesty are not
constitutive of offenses so grave that they warrant the ultimate penalty of
dismissal.[4] Thus, the CSC issued parameters "in order to guide the
disciplining authority in charging the proper offense" and in imposing the
correct penalty.
The resolution classifies dishonesty into three acts: (1) serious, (2) less serious, and (3) simple.
Serious dishonesty is punishable by dismissal.[5] Less serious dishonesty is punishable by suspension for six (6) months and one (1) day to one (1) year for the first offense and dismissal for the second offense.[6] Simple dishonesty is punishable by suspension of one (1) month and one (1) day to six (6) months for the first offense, six (6) months and one (1) day to one (1) year for the second offense, and dismissal for the third offense.[7]
CSC
Resolution No. 06-0538 recognizes that dishonesty is a
grave offense generally punishable by
dismissal from service.[3] Nonetheless, some acts of dishonesty are not
constitutive of offenses so grave that they warrant the ultimate penalty of
dismissal.[4] Thus, the CSC issued parameters "in order to guide the
disciplining authority in charging the proper offense" and in imposing the
correct penalty.The resolution classifies dishonesty into three acts: (1) serious, (2) less serious, and (3) simple.
Serious dishonesty is punishable by dismissal.[5] Less serious dishonesty is punishable by suspension for six (6) months and one (1) day to one (1) year for the first offense and dismissal for the second offense.[6] Simple dishonesty is punishable by suspension of one (1) month and one (1) day to six (6) months for the first offense, six (6) months and one (1) day to one (1) year for the second offense, and dismissal for the third offense.[7]
[1] Corpuz v. Ramiterre, Adm. Matter No. P-04-1779 (Formerly Adm. Matter
No. 03-12-703 RTC) 476 SCRA 108, 121; Office of the Court Administrator v.
Ibay, A.M. No. P-02-1649, November 29, 2002, 393 SCRA 212; and OCAD v. Yan,
A.M. No. P-98-1281, April 27, 2005.
[2] As amended by CSC Resolution No. 06-1009. The amendment, however, only
refers to a clerical error under Section 7.
[3] Id.
[4] Id.
[5] Id.
[6] Id.
[7] Id.