MANILA, Philippines — The Court of Appeals (CA) has ruled that public officials who failed to accomplish accurately their statements of assets, liabilities and net worth (SALN) may be held administratively liable.

In a decision written by Associate Justice Isaias Dicdican, the CA said that the administrative liability for inaccurate SALN attaches even if the omission was not done deliberately.

With the ruling, the CA denied the petition filed by Mario Bravo, assistant secretary for administration, legal and financial affairs of the Department of Science and Technology (DOST).

Bravo challenged the 2010 ruling of the Office of the Ombudsman which found him liable for simple negligence and suspended him for one month without pay for violation of Section 8, in relation to Section 11, of Republic Act No. 6713, otherwise known as the Code of Conduct and Ethical Standards for Public Officials and Employees.

RA 6713 requires public officials to file their SALNs under oath with a disclosure of business interests and financial connections under pain of imprisonment or fine, dismissal or removal, as well as disqualification, from public office.

Bravo was first appointed assistant secretary for financial affairs of the Department of Education, Culture and Sports in 1998. He transferred to the DOST in 2005.

In 2009, Bravo was charged with violating Article 183 of the Revised Penal Code, Section 8 in relation to Section 11 of the R.A. 6713 and Section 2 of the Rules Implementing the Code of Conduct and Ethical Standards for Public Officials and Employees and Dishonesty, Grave Misconduct and Conduct Prejudicial to the Best Interest of the Service.