Other cases wherein the Supreme Court rejected the notion that Section 10 of RA 6713 allows SALNs to be corrected are G.R. Nos. 190580-81 promulgated February 21, 2011 by the high tribunal's Second Division.
The erring official, a treasurer of Parañaque City, claimed that he was entitled to be informed of any error in his SALN and should have been given the opportunity to correct it.
"True, Section 10 of R.A. 6713 provides that when the head of office finds the SALN of a subordinate incomplete or not in the proper form such head of office must call the subordinate’s attention to such omission and give him the chance to rectify the same. But this procedure is an internal office matter," the Supreme Court said.
"The notice and correction referred to in Section 10 are intended merely to ensure that SALNs are 'submitted on time, are complete, and are in proper form.' Obviously, these refer to formal defects in the SALNs," it added.
The court ruling said the charges against the Parañaque official are for falsification of the assets side of his SALNs and for declaring a false net worth.
"These are substantive, not formal defects," the court said. "It would be absurd to require such heads to run a check on the truth of what the SALNs state and require their subordinates to correct whatever lies these contain. The responsibility for truth in those SALNs belongs to the subordinates who prepared them, not to the heads of their offices."
The Decision was penned by J. Roberto Abad and certified by RENATO CORONA less than a year ago!