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]

[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.

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