The Supreme Court ruled that a public official’s negligence in guaranteeing a loan application, without proper verification, constitutes a breach of duty. This decision underscores the importance of due diligence and integrity in public service, preventing fraudulent activities that may harm unsuspecting citizens. The Court emphasized that public servants must be held accountable for their actions and should exhibit the highest degree of honesty and integrity in the performance of their duties, and that failure to uphold these standards warrants disciplinary action.

When a Helping Hand Becomes a Breach of Trust: The Doronio Case

This case revolves around Susan M. Doronio, a Fiscal Controller in the Office of the Court Administrator (OCA), who was found to have negligently guaranteed loan applications for individuals she did not personally know, leading to fraudulent loans being issued in the names of unsuspecting court employees, Alejandrea Guro and Absamen Domocao. The legal question is whether Doronio’s actions constituted neglect of duty, thereby warranting disciplinary action.

The facts of the case reveal that Guro and Domocao discovered that loans had been fraudulently obtained in their names, with Doronio guaranteeing the impostor’s identity to the Government Service Insurance System (GSIS) and Supreme Court Savings and Loan Association (SCSLA). Doronio claimed she had been performing liaison work for years and believed the impostor’s Supreme Court ID was genuine, and she did not have any bad intentions. The Investigating Body found Doronio’s actions to be an irregular practice, and a careless performance of duty as a liaison officer. Doronio’s actions enabled unscrupulous individuals to take advantage of court employees.

“It is never the duty of the liaison officer to guarantee their identities. The only duty of the liaison officer is to make sure that the remittances, loan applications and checks are immediately transmitted to the GSIS/OCA Offices concerned but never to individually release them.”

The Supreme Court agreed with the Investigating Body’s findings, emphasizing that a public servant must exhibit honesty and integrity at all times. The court underscored that Doronio’s actions constituted a neglect of duty. Her failure to exercise due diligence in verifying the identity of the loan applicant led to the fraudulent disbursement of funds. Respondent was negligent in the performance of her duty and was lax in giving her guarantee for the release of the proceeds of the loan, especially since a requirement was lacking.

The Court further clarified that an affidavit of desistance from the complainants does not warrant the dismissal of an administrative case. Public service demands accountability, and administrative proceedings cannot depend on the whims of complainants. As a court employee, Doronio is covered by the Civil Service Law, which provides disciplinary actions for neglect of duty. According to the Administrative Code of 1987, neglect of duty is a ground for disciplinary action. Simple neglect of duty is considered a less grave offense and is punished with suspension for one (1) month and one (1) day to six (6) months for the first offense, and dismissal for the second offense.

This ruling highlights the importance of verifying information and adhering to established procedures. It reminds public officials that they must always prioritize due diligence. This principle applies to any government employee tasked with handling sensitive documents or processing financial transactions.

Ultimately, the Supreme Court’s decision underscores the importance of maintaining integrity and accountability within the Philippine judiciary, reinforcing the principle that public servants must uphold the highest standards of conduct to maintain public trust and confidence.

FAQs

What was the key issue in this case?	The key issue was whether Susan M. Doronio, as a Fiscal Controller, was negligent in guaranteeing loan applications, leading to fraudulent loans being issued, and if so, what disciplinary action was warranted.
What did Susan Doronio do wrong?	Doronio guaranteed loan applications without properly verifying the identity of the applicants, which allowed impostors to obtain loans in the names of unsuspecting court employees.
Why was Doronio held liable despite claiming she was just helping?	The Court emphasized that Doronio had a duty to exercise due diligence as a liaison officer, and her failure to do so constituted neglect of duty, regardless of her intentions.
What is the significance of an affidavit of desistance in this case?	The Court ruled that an affidavit of desistance from the complainants did not warrant the dismissal of the administrative case, as public service demands accountability regardless of the complainants’ wishes.
What penalty did Susan Doronio receive?	Susan M. Doronio was suspended for three (3) months for negligence, with a warning that any repetition of the same would result in a more severe penalty.
What legal principle does this case highlight?	The case underscores the principle that public servants must exhibit honesty and integrity in the performance of their duties and are accountable for their actions, especially when handling sensitive financial transactions.
How does this case relate to the Civil Service Law?	As a court employee, Doronio is covered by the Civil Service Law, which provides disciplinary actions for neglect of duty, including suspension or dismissal, depending on the severity and frequency of the offense.
What was the Court’s direction regarding the deducted loan amounts?	The Fiscal Management Office, Office of the Court Administrator, was directed to cease and desist from deducting the GSIS and SCSLA loans subject of this complaint from the salaries of Alejandrea L. Guro and Absamen C. Domocao.

This case serves as a reminder that public officials must act with utmost care and diligence, especially when handling sensitive financial matters. By holding individuals accountable for their negligence, the Supreme Court reinforces the importance of ethical conduct and integrity in public service.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: ALEJANDREA GURO AND ABSAMEN C. DOMOCAO VS. SUSAN M. DORONIO, A.M. No. 2002-6-SC, February 05, 2003