# Dishonesty and Grave Misconduct: Cases on Principals

Dishonesty needs a lie or deception; grave misconduct needs proof of corruption or intent. Rubenecia, Santos, Dionisio, Corpuz and 2025 RACCS penalties.

This is the Markdown copy of [Dishonesty and Grave Misconduct: Cases on Principals](https://nash.com.ph/blog/principal-dishonesty-grave-misconduct-cases), an article on the NASH Reviewer Blog by Mark Anthony Llego, published Oct 31, 2026, updated Nov 4, 2026. Topics: School leadership, Aspiring school heads. NASH Reviewer is an independent practice platform not affiliated with DepEd, BHROD, or NEAP.

For a public school principal, dishonesty is a false statement or a deception about a material fact, such as a daily time record (DTR) showing a full day at school when the principal was elsewhere. Grave misconduct is breaking an established rule with corruption, a clear intent to violate the law, or a flagrant disregard of established rules, and those elements must be proved. The leading case on the line between grave and simple misconduct is [*Office of the Deputy Ombudsman for Luzon v. Dionisio*](https://lawphil.net/judjuris/juri2017/jul2017/gr_220700_2017.html), G.R. No. 220700, July 10, 2017 (First Division). A principal who leased school land without authority, receipts or bidding was dismissed, even though she argued that the money went to the school. In [*Corpuz v. Cardoza*](https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70576), G.R. No. 253422, June 2, 2026 (Second Division), the Court cut a principal's dismissal to six months' suspension because nothing showed that he kept the money from wood sold off school trees.

Two principals in these cases were cleared of the graver charge: Sevilla of dishonesty and Corpuz of grave misconduct. Both were still penalized for lesser offenses. Of the other cases charted in Figure 1, five ended in dismissal. In three, the dismissal held at every level. In *Santos* and *Dionisio*, the Supreme Court restored it after the Court of Appeals had set it aside.

Under the 2025 Rules on Administrative Cases in the Civil Service (2025 RACCS), in force since August 4, 2025, grave misconduct, serious dishonesty, falsification of an official document and nepotism are punished by dismissal on the first offense. The cases below are nine Supreme Court decisions involving public school principals, from 1995 to 2026, and three related rulings.

## Key findings

- **False attendance records cost a principal his post.** In [*Rubenecia v. Civil Service Commission*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=37092&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 115942, May 31, 1995 (En Banc), a dismissal stood for not keeping a DTR, certifying perfect attendance during an "Official Travel" no one could confirm, recommending a brother-in-law for a utility post and not releasing two teachers' pay on time.
- **A DTR entry is a statement of fact.** In [*Office of the Ombudsman v. Santos*](https://lawphil.net/judjuris/juri2006/mar2006/gr_166116_2006.html), G.R. No. 166116, March 31, 2006 (Second Division), a DTR showing a full day at school while the principal attended a private school's event was dishonesty. Taking home iron sheets from a school project was grave misconduct, and managing a private school broke RA 6713. She was dismissed and fined PHP 5,000.
- **A signed false payroll, and a missed appeal.** In [*Balbastro v. Junio*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=51624&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 154678, July 17, 2007 (Third Division), a dismissal for dishonesty over payrolls naming former students who never worked stood, mainly because she used certiorari instead of a timely appeal.
- **No false statement or intent to deceive, no dishonesty.** In [*Sevilla v. Gocon*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=47423&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 148445, February 16, 2004 (First Division), a principal who did not tell the teacher doing the work that someone else had been appointed head teacher was liable for conduct grossly prejudicial to the service, not dishonesty. Retired, he was fined six months' salary.
- **Good intentions do not excuse a known rule.** In *Dionisio* (2017), leasing school land without authority, taking money without official receipts and skipping bidding was grave misconduct, because the principal knew the rules and went ahead.
- **Grave misconduct needs evidence apart from the rule-breach.** In *Corpuz* (2026), a bakery owner's statement that he bought firewood from the principal did not prove the principal kept the money. The decision may not yet be final.
- **Mitigating circumstances cannot reduce a dismissal.** In [*De la Cruz v. DECS-CAR*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=47292&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 146739, January 16, 2004 (Second Division), 25 years of service did not soften a dismissal for taking money from teachers for appointments. The 2025 RACCS keeps that rule.

## What dishonesty and grave misconduct mean

**Dishonesty.** In *Sevilla*, the Court quoted its earlier definition: dishonesty is "[i]ntentionally making a false statement in any material fact, or practicing or attempting to practice any deception or fraud in securing his examination, registration, appointment or promotion." It implies a "[d]isposition to lie, cheat, deceive, or defraud; untrustworthiness; lack of integrity." The key element is intent.

**Misconduct.** In *Dionisio*, the Court said misconduct "is a transgression of some established and definite rule of action, more particularly, unlawful behavior or gross negligence by the public officer," connected with official duties. What makes it grave: "In order to differentiate gross misconduct from simple misconduct, the elements of corruption, clear intent to violate the law, or flagrant disregard of established rule, must be manifest in the former."

**Corruption.** In *Corpuz*, the Court quoted its definition: corruption "consists in the act of an official or fiduciary person who unlawfully and wrongfully uses his or her station or character to procure some benefit for himself/herself or for another person, contrary to duty and the rights of others."

**Falsification.** The 2025 RACCS makes falsification of an official document a grave offense. When a false document is the means of a dishonest act, the charge is dishonesty alone, "as the act of falsification is already subsumed in the offense of Dishonesty" (Sec. 64(B)(5)).

| Offense | What must be shown | Example from the cases |
|---|---|---|
| Dishonesty | An intentional false statement, or deception or fraud | A DTR showing a full day at school while the principal was at a private school (*Santos*) |
| Grave misconduct | A broken rule, plus corruption, clear intent to violate the law, or flagrant disregard of rules, proved by evidence | Leasing school land, unreceipted money and no bidding, knowing the rules (*Dionisio*) |
| Simple misconduct | A broken rule without those elements | Cutting two trees without permits when permits were secured for the others (*Corpuz*) |
| Simple neglect of duty | Failure to give proper attention to a task, through carelessness or indifference | No record of materials salvaged from a demolished building (*Corpuz*) |
| Conduct grossly prejudicial to the service | Conduct that harms the service; no false statement is needed | Not telling a teacher that someone else held the post she was filling (*Sevilla*) |

## DTRs, travel and attendance: the cases

### Rubenecia v. Civil Service Commission (1995)

Justice Feliciano wrote for a unanimous Court.

**Facts.** Teachers of Catarman National High School in Northern Samar charged their principal, Ruble Rubenecia, with dishonesty, nepotism, oppression and violation of civil service rules. He filed no formal answer but wrote to the CSC Chairman claiming innocence. The CSC took the case over from its Merit System Protection Board and dismissed him in Resolution No. 94-0533. It cleared him of insubordination, because his absences were on approved leave. Its findings, which the Court quoted, were these:

- He admitted not accomplishing his DTR, on an administrative officer's suggestion. The CSC said: "As the principal of a national high School, he is expected to know the basic civil service law, rules, and regulations."
- He was charged with "misrepresenting that he was on 'Official Travel' to Baguio City to attend a three-week seminar" and with showing perfect attendance in his CSC Form No. 7 for October 1988. The Schools Division Superintendent certified he had no official knowledge of the travel, and the Bureau of Secondary Schools reported no DECS seminar for principals at that time.
- He recommended his brother-in-law as a utility worker. The CSC held that "the recommending authority is also prohibited from recommending the appointment to a non-teaching position of his relatives within the prohibited degree."
- He did not give on time the money benefits due two teachers: salary differentials, salaries and vacation pay. The CSC found this was oppression; he presented no evidence against it.

**Issues.** Could the CSC take the case from the Board? Was he denied due process?

**Ruling.** The Court dismissed the petition. The Board was part of the CSC's internal organization, and Rubenecia had pleaded before the CSC. On due process, "Denial of due process cannot be successfully invoked by a party who has had the opportunity to be heard on his motion for reconsideration." The CSC's decision was "supported by substantial evidence," and the Court would not weigh the evidence again.

**Why it matters.** The CSC held, and the Court let stand, that a principal cannot excuse a missing DTR by pointing to an administrative officer's suggestion. A claim of official travel needs proof that the activity took place.

**Later history.** Under the 2025 RACCS, nepotism is punished by dismissal and oppression by six months and one day to one year of suspension for a first offense. See [Promotion Protests and Nepotism](https://nash.com.ph/blog/principal-promotion-protest-nepotism-cases) and [Oppression Cases](https://nash.com.ph/blog/principal-oppression-teachers-cases).

### Office of the Ombudsman v. Santos (2006)

Justice Puno wrote the decision.

**Facts.** In 1997 a teacher at Lagro Elementary School in Quezon City complained to the Ombudsman against her principal, Florentina Santos.

- **The DTR.** Santos's DTR for August 20, 1997 showed her at Lagro from 6:45 a.m. to 7:15 p.m. Witnesses placed her that morning at a Linggo ng Wika celebration at a Golden Child Montessori annex in Bulacan. She said she had asked the District Supervisor, who did not object.
- **The private school.** She was an incorporator of Golden Child Montessori and its President and Chairman of the Board. Witnesses testified that she handled its finances, signed checks and issued its memoranda.
- **The iron sheets.** Witnesses testified that galvanized iron sheets from a comfort room renovation were taken to her house on her instructions. She said the contractor sold her the excess at cost.
- **The guard.** A security guard testified that she refused to give him his wife's emergency call.

The Ombudsman found dishonesty, violation of Sec. 4(c) of RA 6713 and grave misconduct, and dismissed her. It found that she made it appear "that she was present for work when in fact she was absent therefrom," and that "the respondent took government property for her own personal benefit which constitutes Grave Misconduct." It found no violation in her owning a private school. The Court of Appeals reversed for lack of substantial evidence.

**Issue.** Did substantial evidence support the Ombudsman?

**Ruling.** The Court reinstated the Ombudsman's decision and affirmed its findings. It differed on one point: "By actively participating in the management of Golden Child Montessori, a private school, while serving as Principal of Lagro Elementary School, a government school, respondent has transgressed the provisions of Section 7 (b) (2) of R.A. 6713." It added a PHP 5,000 fine under Sec. 11 of RA 6713.

**Why it matters.** The private-school ruling rested on her active management, not on ownership alone.

**Later history.** RA 6713 has not been amended.

### A teacher's DTR in criminal court: Layug v. Sandiganbayan (2000)

In [*Layug v. Sandiganbayan*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=42032&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. Nos. 121047-57, August 16, 2000 (First Division), a teacher whose principal had complained against him to the Tanodbayan was convicted by the Sandiganbayan of eleven counts of falsifying his DTRs. The Supreme Court acquitted him: "in the prosecution of cases involving falsification of daily time records, it is imperative that there be proof of damage to the government." He had not been paid for those months, he did report to the school, and his good faith was not disproved. The Court remarked that his conduct might be grounds for an administrative case, but that remark is obiter. The acquittal decided only the criminal charge.

## Running a private school or business on the side

In *Santos*, the Court explained that "public servants are expected to devote their undivided attention to their public duties." [RA 6713](https://lawphil.net/statutes/repacts/ra1989/ra_6713_1989.html), Sec. 7(b), bars officials from two things that matter here:

- **Sec. 7(b)(1):** to "Own, control, manage or accept employment as officer, employee, consultant, counsel, broker, agent, trustee or nominee in any private enterprise regulated, supervised or licensed by their office unless expressly allowed by law."
- **Sec. 7(b)(2):** to "Engage in the private practice of their profession unless authorized by the Constitution or law, provided, that such practice will not conflict or tend to conflict with their official functions."

The bars last one year after leaving office; for Sec. 7(b)(2), only for practice "in connection with any matter before the office he used to be with."

The 2025 RACCS grades outside activity. Owning, controlling or managing a private enterprise regulated, supervised or licensed by one's office is a grave offense, punished by six months and one day to one year of suspension for a first offense (Sec. 63(A)(2)(m)). Not resigning or divesting when a conflict of interest arises is less grave (Sec. 63(B)(4)). Unauthorized private practice of one's profession, and private business without the required permission, are light offenses (Sec. 63(C)(3) and (12)). Which applies depends on the facts. In *Santos*, the outside activity came with dishonesty and grave misconduct, and those drove the dismissal.

## When it is dishonesty, and when it is not

### Balbastro v. Junio (2007)

Justice Austria-Martinez wrote the decision.

**Facts.** In 2000, ten former students of Iloilo City National High School filed criminal and administrative cases against Principal III Corazon Balbastro and three school officials. Daily wage payrolls showed the students working on festival costumes, props and a toilet repair at PHP 120 a day; the students said they were never hired and never signed for or received the money. Balbastro said she signed payrolls the accounting staff prepared, believed the payees were students in the school's festival group, and received nothing. At the Ombudsman's hearing, she and two co-respondents walked out and refused to present evidence. The Ombudsman (Visayas) dismissed her and two others for dishonesty, and suspended the acting disbursing officer for a month. It found that "Corazon Balbastro even signified her assurance by signing the payrolls." Balbastro filed a certiorari petition in the Court of Appeals 52 days after receiving the denial of her motion for reconsideration, and it was dismissed as the wrong remedy.

**Issue.** Did the Court of Appeals err?

**Ruling.** No. Ombudsman administrative decisions are appealed to the Court of Appeals under Rule 43 within 15 days, and "certiorari under Rule 65 cannot be resorted to as a substitute for the lost remedy of appeal." The Court rejected her claim that the Ombudsman could only recommend penalties, said the findings rested on substantial evidence, and denied the petition.

**Why it matters.** The case was decided mainly on procedure, but the Ombudsman's finding stood, and that finding treated her signature on the payrolls as her assurance that they were genuine. Appeal deadlines are in [Preventive Suspension, Appeals and Back Pay](https://nash.com.ph/blog/principal-preventive-suspension-appeal-back-pay).

**Later history.** In a separate case, [*Balbastro v. Commission on Audit, Regional Office No. VI*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=52637&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 171481, June 30, 2008 (En Banc), the Court upheld her dismissal for grave misconduct in a case that grew out of a COA audit of the school's accounts; see [Can a Principal Be Jailed Over School Funds?](https://nash.com.ph/blog/principal-malversation-graft-school-funds).

### Sevilla v. Gocon (2004): an omission without intent to deceive

The CSC had dismissed a Principal IV of Quezon National High School for dishonesty over a head teacher's reclassification, and the Court of Appeals agreed. The Supreme Court accepted the Court of Appeals' finding that the head teacher, not the principal, altered the request, and held that "he is administratively liable for his omission which, however, did not amount to dishonesty, as he had made no false statement." It added that "no deliberate intent to mislead, deceive or defraud can be read from the circumstances of this case." His failure to inform the teacher doing the work and to remedy the prejudice to her was conduct grossly prejudicial to the service. He had retired, so the Court fined him six months' salary, deducted from his retirement benefits. The digest is in [Promotion Protests and Nepotism](https://nash.com.ph/blog/principal-promotion-protest-nepotism-cases).

### Office of the Ombudsman v. Madriaga (2006): two respondents, no ruling on the charges

In [*Office of the Ombudsman v. Madriaga*](https://lawphil.net/judjuris/juri2006/sep2006/gr_164316_2006.html), G.R. No. 164316, September 27, 2006 (Third Division), the Ombudsman found Principal Gertrudes Madriaga liable under RA 6713, Sec. 5(a), for not promptly answering a request for canteen financial statements, and suspended her and Ana Marie Bernardo, a teacher designated canteen manager, for six months each for conduct grossly prejudicial to the service. The Supreme Court ruled only that the Ombudsman's penalties are not merely recommendatory, and remanded without ruling on the charges. See [Unauthorized School Fees](https://nash.com.ph/blog/unauthorized-school-fees-principal-cases).

## Grave or simple misconduct: Dionisio and Corpuz

### Office of the Deputy Ombudsman for Luzon v. Dionisio (2017)

Justice Perlas-Bernabe wrote the decision.

**Facts.** The respondents were Eufrocina Dionisio, principal of Barasoain Memorial Elementary School in Malolos, and Winifredo Molina, president of its Teachers' Association. In 2009 a couple leased part of the school grounds for a drugstore under an agreement Molina signed for the Teachers' Association. The couple complained to the Ombudsman in 2010. They said Dionisio told them the lease "might take a long and complicated procedure if they follow the rules of the Department of Education," and that they paid large sums in advance rent and a "donation." The Schools Division Superintendent ordered the drugstore's operation held in abeyance. The respondents said the money was a donation spent on a canteen and equipment, in good faith.

- **Ombudsman, 2012:** simple misconduct, three months' suspension. It dismissed the charges against six other teachers, who had only signed a ratification.
- **Ombudsman, 2013, on reconsideration:** grave misconduct and dismissal. The respondents could not explain how PHP 600,000 in advance rent and PHP 680,000 in donations were spent for public purposes, issued no official receipts and held no bidding.
- **Court of Appeals, 2015:** back to simple misconduct. It found no corruption, accepting that the funds went to the school, and noted that the Sangguniang Panlalawigan of Bulacan ratified the agreement in December 2013.

**Issue.** Was the liability only simple misconduct?

**Ruling.** No; it was grave misconduct, for three reasons.

1. **No authority to lease.** The site belonged to the Provincial Government of Bulacan, and under Sec. 18 of the Local Government Code the local government unit holds the power to lease its proprietary property. The province's ratification came more than four years after the agreement, and after the Ombudsman's 2013 order: "a mere afterthought."
2. **No accounting.** The respondents "failed to submit official receipts and other documents that would support their claim" that the money was spent for public purposes.
3. **No bidding.** RA 9184 required competitive bidding, and no alternative method was justified.

The Court said that "respondents cannot hide behind the cloak of ignorance or lack of familiarity with the foregoing laws and policies." Dionisio did not deny her remark about a long procedure, and the respondents argued that the school benefited. Both showed "clear intent to violate the law and/or flagrant disregard of established rules." The Court dismissed both respondents, with cancellation of eligibility, forfeiture of retirement and other benefits except accrued leave credits, and perpetual disqualification from re-employment in government. It added: "while respondents' intentions may be noble and may have indeed benefited the school, the Court cannot turn a blind eye on respondents' blatant disregard of existing rules and regulations lest the Court sets a dangerous precedent."

**Why it matters.** The Court did not find that Dionisio pocketed the money. Grave misconduct rested on clear intent and flagrant disregard, shown by her own words and conduct.

**Later history.** *Dionisio* applied the 1999 Uniform Rules (URACCS) and RA 9184. RA 9184 was repealed by [RA 12009](https://lawphil.net/statutes/repacts/ra2024/ra_12009_2024.html), the New Government Procurement Act (Sec. 115). Grave misconduct still means dismissal under the 2025 RACCS.

### Corpuz v. Cardoza (2026)

Justice Kho, Jr. wrote the decision, with Senior Associate Justice Leonen and Justices Lazaro-Javier and Villanueva concurring.

**Facts.** Five complainants charged Melencio Corpuz, principal of Bagong Sikat Elementary School and later of San Jose Pilot Elementary School in San Jose, Occidental Mindoro, with grave misconduct and violation of RA 3571, the law against cutting trees in school premises and other public places. They alleged that he had trees cut without permits, demolished a five-classroom building without an order, took materials home and sold wood. He said he had permits, that the building was damaged by the elements and termites, and that the wood became 50 armchairs, other furniture and the chainsaw operator's pay.

The Ombudsman cleared him of the most serious allegations: there was no proof that he misappropriated the mahogany lumber or the demolished building's materials, and a municipal demolition permit had been issued. It found him guilty of grave misconduct, because a bakery bought PHP 2,800 of wood and he did not show that the proceeds reached the school; simple neglect of duty, for no inventory of salvaged materials; and simple misconduct, for cutting one acacia and one mahogany tree without permits. It dismissed him, and the Court of Appeals affirmed.

**Issue.** Was he liable for all three offenses?

**Ruling.** The Court partly granted the petition.

- **Simple neglect, affirmed.** He "failed to account for the salvaged materials and did not maintain a record of the demolished school properties," as DepEd Order No. 107, s. 2010 requires.
- **Simple misconduct for the two trees, affirmed.** He had permits for the other trees, so the lapse "merely reflected a lack of prudence in securing permits for said specific trees, rather than an intentional defiance of or disregard for established regulations."
- **Grave misconduct, not proved.** "The statement from Lopez Bakery does not, by and of itself, prove that Corpuz personally received the proceeds and appropriated them for himself." And: "Without evidence such as receipts, audit reports, or testimony from the school treasurer confirming non-remittance, the Ombudsman's conclusion that Corpuz profited from the proceeds is purely speculative." He had a teacher's sworn statement that the money paid the laborers and chainsaw operator through the PTA President, and certifications from teachers who received lumber for classroom cabinets.

Grave misconduct "is not mere failure to comply with the law." Quoting *Yamson v. Castro*: "There must be evidence, independent of the petitioners' failure to comply with the rules, which will lead to the foregone conclusion that it was deliberate and was done precisely to procure some benefit for themselves or for another person." The sale was simple misconduct, so he was liable for two counts of simple misconduct and one of simple neglect.

**Penalty.** Under the 2011 Revised Rules (RRACCS), in force when the complaint was filed, both offenses were less grave. The extra counts aggravated, a first offense mitigated, and with more aggravating circumstances the maximum applied: six months' suspension, converted to a fine of six months' salary if he has left the service.

**Why it matters.** The Court required proof that Corpuz kept the money, not an inference from missing papers. His lapses in handling the sale proceeds and the salvaged materials, and the two trees cut without permits, still made him liable.

**Later history.** *Corpuz* is the Court's latest word, as of October 2026, though it may not yet be final. *Corpuz* does not cite *Dionisio*. Under the 2025 RACCS both offenses remain less grave, and Sec. 71 imposes the maximum for two or more counts of the same offense "regardless of the presence of any mitigating circumstance."

### Dionisio and Corpuz side by side

| | *Dionisio* (2017) | *Corpuz* (2026) |
|---|---|---|
| Acts | Leased part of the school site; took advance rent and a "donation"; built a canteen and bought equipment | Had school trees cut, two without permits; sold wood; demolished a building without recording salvaged materials |
| Money | PHP 600,000 rent and PHP 680,000 donations, per the Ombudsman's order | PHP 2,800 in firewood sales |
| Evidence of intent or corruption | Her remark about a "long and complicated procedure"; no receipts or documents; the defense that the school benefited | None beyond the sale; a sworn statement that the money paid workers |
| Rules broken | Local Government Code, Sec. 18; accountability for funds; RA 9184 | Tree-cutting permits; disposal of public property; DepEd Order No. 107, s. 2010 |
| Finding | Grave misconduct | Two counts of simple misconduct, one of simple neglect |
| Penalty | Dismissal with accessory penalties | Six months' suspension, or a fine if separated |

## School property: land, trees and salvaged materials

| Property | What went wrong | What to do |
|---|---|---|
| School land | A principal leased part of the site (*Dionisio*) | Sign no lease. Refer offers in writing to the Schools Division Office and accept no money tied to them |
| Money received | No official receipts (*Dionisio*); no record of where sale money went (*Corpuz*) | Issue official receipts for everything and keep the liquidation papers |
| Purchases | Canteen built and equipment bought without bidding (*Dionisio*) | Procure through the Bids and Awards Committee under RA 12009 |
| Trees | Two cut without permits (*Corpuz*) | Get and file a permit for every tree |
| Demolished buildings | No inventory of salvaged materials (*Corpuz*) | Follow DepEd Order No. 107, s. 2010 |
| Leftover materials | Iron sheets taken to the principal's house (*Santos*) | Return leftovers to school stock and record them |

[DepEd Order No. 107, s. 2010](https://www.deped.gov.ph/2010/10/20/do-107-s-2010-revised-guidelines-on-the-condemnation-and-demolition-of-school-buildings/) requires that when demolition is done by administration, "the school head shall list all the salvaged materials and shall submit a Waste Material Report to the respective Division Office." The school head informs the Commission on Audit, asks in writing for relief of accountability, and files everything in a folder marked "Condemned/Demolished School Properties." [DepEd Order No. 018, s. 2023](https://www.deped.gov.ph/2023/07/21/july-20-2023-do-018-s-2023-revised-multi-year-guidelines-on-the-allocation-receipt-utilization-monitoring-and-reporting-of-the-basic-education-facilities-funds-beff/) still cites it, and as of October 2026 no DepEd order has replaced it.

## How the penalty changed from one level to the next

Figure 1 traces seven of these decisions. The Supreme Court changed the outcome it reviewed in four: upward in *Santos* and *Dionisio*, downward in *Sevilla* and *Corpuz*.

![Seven small charts showing each case's penalty at the Ombudsman or CSC, the Court of Appeals and the Supreme Court. Three stay at dismissal; Sevilla and Corpuz end lower; Santos and Dionisio end at dismissal after a lower ruling.](https://nash.com.ph/blog/_astro/dishonesty-penalty-path.B7nb9eEq_2iVFJC.webp)

*Figure 1. The penalty at each level in seven Supreme Court decisions on public school principals charged with dishonesty or misconduct, 1995 to 2026. Data: Rubenecia, de la Cruz, Sevilla, Santos, Balbastro v. Junio, Dionisio and Corpuz; Madriaga is left out because the Court remanded it without ruling on the charges. Chart: © 2026 Mark Anthony Llego, NASH Reviewer. [Download the full-resolution chart (PNG)](https://nash.com.ph/blog/charts/sc-cases/dishonesty-penalty-path.png) or [its data (CSV)](https://nash.com.ph/blog/charts/sc-cases/dishonesty-penalty-path.csv).*

## Penalties under the 2025 RACCS

These cases applied older rules, from the Civil Service Act of 1959 to the 2011 RRACCS. The [2025 RACCS](https://csc.gov.ph/phocadownload/userupload/irmo/mc/2025/MC%20No.%2012%20s.%202025.pdf), circulated by CSC Memorandum Circular No. 12, s. 2025, took effect on August 4, 2025 and repealed the 2017 RACCS (Sec. 156). It also governs further proceedings in pending cases, unless the CSC finds that unfeasible or unjust (Sec. 158).

| Offense | Class (2025 RACCS) | First offense | Second offense | Third offense |
|---|---|---|---|---|
| Serious dishonesty | Grave, Sec. 63(A)(1) | Dismissal | | |
| Grave misconduct | Grave, Sec. 63(A)(1) | Dismissal | | |
| Falsification of official document | Grave, Sec. 63(A)(1) | Dismissal | | |
| Nepotism | Grave, Sec. 63(A)(1) | Dismissal | | |
| Less serious dishonesty | Grave, Sec. 63(A)(2) | Suspension, 6 months and 1 day to 1 year | Dismissal | |
| Conduct prejudicial to the best interest of the service | Grave, Sec. 63(A)(2) | Suspension, 6 months and 1 day to 1 year | Dismissal | |
| Oppression | Grave, Sec. 63(A)(2) | Suspension, 6 months and 1 day to 1 year | Dismissal | |
| Loafing from duty during regular office hours | Grave, Sec. 63(A)(2) | Suspension, 6 months and 1 day to 1 year | Dismissal | |
| Simple dishonesty | Less grave, Sec. 63(B) | Suspension, 1 month and 1 day to 6 months | Suspension, 6 months and 1 day to 1 year | Dismissal |
| Simple misconduct | Less grave, Sec. 63(B) | Suspension, 1 month and 1 day to 6 months | Dismissal | |
| Simple neglect of duty | Less grave, Sec. 63(B) | Suspension, 1 month and 1 day to 6 months | Dismissal | |
| Failure to act promptly on letters and requests within 15 working days | Light, Sec. 63(C) | Reprimand | Suspension, 1 to 30 days | Dismissal |

**Three tiers of dishonesty.** Sec. 64(B) sorts dishonesty by attendant circumstances:

- **Serious (dismissal):** (a) serious damage and grave prejudice to the government, such as tarnishing the office's integrity or affecting its operations; (b) grave abuse of authority; (c) an accountable officer's act directly involving property, accountable forms or money he or she is directly accountable for, with "evident intent to commit material gain, graft, and corruption"; (d) moral depravity, whether or not in the performance of duties; (e) a civil service examination irregularity or fake civil service eligibility; (f) misrepresented qualifications or fake credentials to qualify for a position; (g) other analogous circumstances.
- **Less serious (first offense: six months and one day to one year):** (a) damage and prejudice to the government not serious enough for the first tier; (b) money or government property involved, which the respondent, not an accountable officer, restitutes; (c) taking advantage of one's position, without personal gain; (d) personal gain, without taking advantage of one's position; (e) other analogous circumstances.
- **Simple (first offense: one month and one day to six months):** (a) no direct relation to one's duties, or no damage or prejudice to the government, without moral depravity; (b) a falsified official document whose information is unrelated to one's employment, or that caused no damage or prejudice to the government, without moral depravity; (c) no use of position, no personal gain and no damage; (d) other analogous circumstances.

A false DTR can fall into any tier, depending on what it caused and how it was done.

**Rules on imposing the penalty.**

- **Dismissal cannot be mitigated.** Sec. 67 allows mitigating and aggravating circumstances "Except for offenses punishable by dismissal from the service," and Sec. 68 says: "Dismissal, being an indivisible penalty, may neither be mitigated nor aggravated, unless allowed by law." This matches *De la Cruz*, where a Principal I in Abra was dismissed for promising teachers appointments, transfers and promotions for money; despite her 25 years of service, "the penalty of dismissal is an indivisible penalty." The digest is in [Promotion Protests and Nepotism](https://nash.com.ph/blog/principal-promotion-protest-nepotism-cases).
- **Different offenses:** the most serious sets the penalty, and the rest aggravate (Sec. 70).
- **Several counts of one offense:** "In case the respondent is found guilty of two or more counts of the same offense, the penalty shall be imposed in the maximum regardless of the presence of any mitigating circumstance" (Sec. 71).
- **Retired respondents:** a suspension becomes a fine, "which in no case shall exceed an amount equivalent to six (6) months' salary" (Sec. 66(a)(4)), as in *Sevilla* and *Corpuz*.
- **What dismissal takes away:** eligibility, the right to hold public office, civil service examinations and retirement benefits. Terminal leave benefits and personal GSIS contributions are not forfeited (Sec. 73(a)).

The full table of offenses and penalties is in [DepEd Administrative Offenses and Penalties in 2026](https://nash.com.ph/blog/deped-administrative-offenses-penalties).

## Criminal cases, execution and repeat complaints

- **A dismissed criminal complaint does not end the administrative case.** In *de la Cruz*, the Ombudsman had dismissed a criminal complaint over the same acts. The Court held: "Dismissal of the criminal case does not foreclose administrative action involving the same facts."
- **A dismissal may be executed pending appeal.** In [*Cucharo v. Subido*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=22365&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. L-27887, February 22, 1971, a former principal who claimed a senior teacher eligibility on his promotion to district supervisor was dismissed for serious misconduct: falsification of a civil service rating card that showed a passing mark in an examination he had failed. He denied making the alterations. The Court upheld immediate execution in the public interest, with back salaries if he were later exonerated. It did not review the falsification finding, and dismissed his appeal from the trial court's dismissal of his petition, because he had not exhausted administrative remedies. Fake eligibility is now serious dishonesty (2025 RACCS, Sec. 64(B)(1)(e)); current execution rules are in [Preventive Suspension, Appeals and Back Pay](https://nash.com.ph/blog/principal-preventive-suspension-appeal-back-pay).
- **The same act cannot be charged again and again.** In [*Civil Service Commission v. Soliva*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=69308&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 275125, July 30, 2025 (Second Division), res judicata barred a third complaint against a head teacher over a relationship for which the CSC and DepEd had already penalized her. "Jurisprudence confirms that the concept of res judicata is applicable to administrative cases as well." Senior Associate Justice Leonen, concurring, added that the established facts did not show the offenses charged.

## What this means for school heads

**Your own attendance.**

- Fill in your DTR daily with true times, whatever anyone advises (*Rubenecia*).
- Before official travel, get a written travel authority, and keep proof the activity happened.
- Never log yourself at school while at a private function. File leave instead (*Santos*).

**What you sign.**

- Check that payees exist and the work was done before signing a payroll (*Balbastro*).
- Do not certify a teacher's DTR you know is wrong; ask for the supporting record.

**Outside work and relatives.**

- Get written permission, through your Schools Division Office, before any outside work, and do not manage a private school (*Santos*).
- Do not recommend a relative within the prohibited degree for a non-teaching post (*Rubenecia*).

**School property and money.**

- Sign no lease of the school site, and accept no "donation" tied to one (*Dionisio*).
- Issue official receipts and keep liquidation papers; see [DepEd school MOOE](https://nash.com.ph/blog/deped-school-mooe).
- Procure through the Bids and Awards Committee under RA 12009.
- Secure a permit for every tree, and follow DepEd Order No. 107, s. 2010 when a building is demolished (*Corpuz*).

**People.**

- Release teachers' pay and benefits on time (*Rubenecia*).
- Tell staff about appointments that affect their work (*Sevilla*).
- Answer written requests, including for financial statements, within 15 working days (RA 6713, Sec. 5(a)).

**If you are charged.** Answer, attend hearings and present evidence; then move for reconsideration, which Ombudsman rules require before any appeal, and appeal on time through the right remedy (*Balbastro*). Consult your Schools Division Office's legal unit or a lawyer.

See also [PPSSH Domain 2, Managing School Operations and Resources](https://nash.com.ph/blog/ppssh-domain-2-managing-school-operations), [school head ethics and internal control](https://nash.com.ph/blog/school-head-ethics-internal-control), [school human resource management](https://nash.com.ph/blog/school-head-human-resource-management) and [the school head's duties under RA 9155](https://nash.com.ph/blog/ra-9155-school-head-duties).

## How the NASH may test this

The two items below are original practice items, scored 3 (Relational), 2 (Multistructural), 1 (Unistructural) or 0 (Prestructural). An option that breaks a rule scores 0.

### Question 1

*Indicator 2.3.2, School facilities and equipment. Career Stage 2, Situational, Moderate.*

You are the principal of a public elementary school whose site is owned by the provincial government. A local businessman offers to rent a vacant corner of the grounds for a pharmacy at PHP 10,000 a month, paid one year in advance, and the PTA president supports the plan because the rent could buy computers. What is the most appropriate action?

- **A.** Accept the advance as a donation from the businessman to the school, issue an acknowledgment receipt, and let him start building while the division reviews the proposed lease.
- **B.** Decline the offer politely and tell the businessman that the school does not rent out any part of its grounds, so the matter can be closed at the school level.
- **C.** Refer the offer in writing to the Schools Division Office and wait for its advice before acting, accepting no money from the businessman while the referral is pending.
- **D.** Explain that you have no authority to lease the site, refer the offer in writing to the Schools Division Office for action with the province that owns it, accept no money tied to the offer, and keep the referral on file.

**Answer and explanation**

**Best answer: D.** Points: A = 0, B = 1, C = 2, D = 3.

- **A (0 points, Prestructural).** Taking advance rent dressed as a donation and letting construction start without authority repeats what *Dionisio* held to be grave misconduct.
- **B (1 point, Unistructural).** Declining is lawful, but it informs no one who can decide and leaves no record.
- **C (2 points, Multistructural).** The referral and the refusal of money are right, but it misses that the school head has no authority to lease and that the owner must act.
- **D (3 points, Relational).** It connects the school head's lack of authority, the owner's power to lease, the bar on taking money, and the record.

**Why.** In *Office of the Deputy Ombudsman for Luzon v. Dionisio* (G.R. No. 220700, July 10, 2017), a principal leased part of a school site owned by the province. The Court held that under Sec. 18 of the Local Government Code the local government unit holds the power to lease such property, and called a later ratification "a mere afterthought." The claimed benefit to the school did not help: "while respondents' intentions may be noble and may have indeed benefited the school, the Court cannot turn a blind eye on respondents' blatant disregard of existing rules and regulations." Grave misconduct is punished by dismissal under the 2025 RACCS, Sec. 63(A)(1).

*Indicator 2.3.2: Manage school facilities and equipment in adherence to policies, guidelines and issuances on acquisition, recording, utilization, repair and maintenance, storage and disposal.*

*Sources: Office of the Deputy Ombudsman for Luzon v. Dionisio, G.R. No. 220700, July 10, 2017; RA 7160, Sec. 18; 2025 RACCS, Sec. 63(A)(1); DepEd Order No. 024, s. 2020.*

### Question 2

*Indicator 2.4.1, Management of staff. Career Stage 1, Conceptual, Moderate.*

A teacher reports that the school's head teacher sold scrap iron from a demolished classroom to a junk shop. The junk shop owner's signed statement says he paid the head teacher PHP 3,000. The head teacher says he handed the money to the PTA treasurer to pay the workers who hauled the debris, and the treasurer confirms it, but no receipts were issued and no inventory of the salvaged materials was made. Which assessment is most consistent with the Supreme Court's rulings?

- **A.** The missing inventory and the unreceipted sale are administrative lapses, but grave misconduct needs evidence, apart from the lapses, of corruption, clear intent or flagrant disregard; on these facts the likelier offenses are simple misconduct and simple neglect, which still carry suspension.
- **B.** The missing inventory is simple neglect of duty under the condemnation and demolition guidelines, and whether the sale is grave misconduct depends only on whether the PTA treasurer can show where the money went.
- **C.** Any sale of school property without authority is grave misconduct, because every head teacher is presumed to know the rules on disposal, so the head teacher should expect dismissal.
- **D.** Because the money went to the PTA for a school purpose, no rule was broken, so the teacher's report can be filed away without any further action by the school.

**Answer and explanation**

**Best answer: A.** Points: A = 3, B = 2, C = 1, D = 0.

- **A (3 points, Relational).** It separates the lapses from the graver charge, states the test for grave misconduct, and draws the result that follows.
- **B (2 points, Multistructural).** The neglect finding is right, but it makes grave misconduct turn on whether the treasurer can account for the money, when the Court requires evidence of corruption or intent.
- **C (1 point, Unistructural).** It sees that the sale broke a rule, but treats every breach as grave, which *Corpuz* rejected.
- **D (0 points, Prestructural).** It ignores the lapses the Court penalized in *Corpuz* and leaves a report of a possible offense unacted on.

**Why.** In *Corpuz v. Cardoza* (G.R. No. 253422, June 2, 2026), a buyer's statement did not prove that the principal kept the money: "Without evidence such as receipts, audit reports, or testimony from the school treasurer confirming non-remittance, the Ombudsman's conclusion that Corpuz profited from the proceeds is purely speculative." Quoting *Yamson v. Castro*, the Court required "evidence, independent of the petitioners' failure to comply with the rules," and found simple misconduct and simple neglect, the latter under DepEd Order No. 107, s. 2010. Both are less grave offenses under the 2025 RACCS, Sec. 63(B).

*Indicator 2.4.1: Demonstrate knowledge and understanding of laws, policies, guidelines and issuances on managing school staff.*

*Sources: Corpuz v. Cardoza, G.R. No. 253422, June 2, 2026; DepEd Order No. 107, s. 2010; 2025 RACCS, Sec. 63(B); DepEd Order No. 024, s. 2020.*

Nothing in this guide reproduces or predicts examination content.

## Frequently asked questions

### Is a wrong entry in a DTR always dishonesty?

No. Dishonesty needs an intentional false statement or deception (*Sevilla v. Gocon*, 2004). A DTR showing a full day at school while the principal was elsewhere was dishonesty in *Office of the Ombudsman v. Santos* (2006). In *Layug v. Sandiganbayan* (2000), the Court held that a criminal conviction for falsifying a DTR needs proof of damage to the government.

### Can a public school principal own or run a private school?

Managing one was held a violation. In *Santos* (2006), a principal who was President and Chairman of a private school and managed it broke Sec. 7(b)(2) of RA 6713; the ruling rested on her management, not ownership alone. Get written permission before any outside work.

### What is the difference between grave and simple misconduct?

Grave misconduct needs corruption, a clear intent to violate the law, or a flagrant disregard of established rules, shown by evidence beyond the rule-breach itself. In *Dionisio* (2017), a principal who knew the rules on leasing school land and went ahead was dismissed. In *Corpuz v. Cardoza* (2026), a principal who cut two trees without permits, sold wood without following the rules on handling the proceeds, and kept no record of salvaged materials was ordered suspended for six months.

### Can long service or good intentions reduce a dismissal?

No. In *De la Cruz v. DECS-CAR* (2004), dismissal was held an indivisible penalty despite 25 years of service. In *Dionisio* (2017), the claim that the money benefited the school did not excuse the principal's disregard of the rules. The 2025 RACCS, Secs. 67 and 68, keeps both points.

### Can a principal who has retired still be penalized?

Yes. In *Sevilla* (2004), the Court fined a retired principal six months' salary, deducted from his retirement benefits, instead of suspending him, and *Corpuz* (2026) ordered the same conversion if he had left the service. The 2025 RACCS, Sec. 66(a)(4), caps such a fine at six months' salary.

## Download the data

- [dishonesty-penalty-path.csv](https://nash.com.ph/blog/charts/sc-cases/dishonesty-penalty-path.csv): the ruling and penalty at each level in seven Supreme Court decisions.

The CSVs and charts may be reused only with written permission: email [support@nash.com.ph](mailto:support@nash.com.ph). The decisions themselves are public records of the Supreme Court, which you can cite directly.

## Sources

**Supreme Court decisions:**

- *Cucharo v. Subido*, G.R. No. L-27887, February 22, 1971. [Supreme Court E-Library](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=22365&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0).
- *Rubenecia v. Civil Service Commission*, G.R. No. 115942, May 31, 1995 (En Banc). [Supreme Court E-Library](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=37092&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0).
- *Layug v. Sandiganbayan*, G.R. Nos. 121047-57, August 16, 2000 (First Division). [Supreme Court E-Library](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=42032&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0).
- *De la Cruz v. Department of Education, Culture and Sports-Cordillera Administrative Region*, G.R. No. 146739, January 16, 2004 (Second Division). [Supreme Court E-Library](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=47292&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0).
- *Sevilla v. Gocon*, G.R. No. 148445, February 16, 2004 (First Division). [Supreme Court E-Library](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=47423&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0).
- *Office of the Ombudsman v. Santos*, G.R. No. 166116, March 31, 2006 (Second Division). [Lawphil](https://lawphil.net/judjuris/juri2006/mar2006/gr_166116_2006.html).
- *Office of the Ombudsman v. Madriaga*, G.R. No. 164316, September 27, 2006 (Third Division). [Lawphil](https://lawphil.net/judjuris/juri2006/sep2006/gr_164316_2006.html).
- *Balbastro v. Junio*, G.R. No. 154678, July 17, 2007 (Third Division). [Supreme Court E-Library](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=51624&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0).
- *Balbastro v. Commission on Audit, Regional Office No. VI*, G.R. No. 171481, June 30, 2008 (En Banc). [Supreme Court E-Library](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=52637&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0).
- *Office of the Deputy Ombudsman for Luzon v. Dionisio*, G.R. No. 220700, July 10, 2017 (First Division). [Lawphil](https://lawphil.net/judjuris/juri2017/jul2017/gr_220700_2017.html).
- *Civil Service Commission v. Soliva*, G.R. No. 275125, July 30, 2025 (Second Division). [Supreme Court E-Library](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=69308&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0).
- *Corpuz v. Cardoza*, G.R. No. 253422, June 2, 2026 (Second Division). [Supreme Court E-Library](https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70576).

**Laws and rules:**

- Civil Service Commission, [2025 Rules on Administrative Cases in the Civil Service](https://csc.gov.ph/phocadownload/userupload/irmo/mc/2025/MC%20No.%2012%20s.%202025.pdf) (CSC Resolution No. 2500357, April 30, 2025; CSC Memorandum Circular No. 12, s. 2025), Secs. 63, 64(B), 66, 67, 68, 70, 71, 73, 156, 158 and 159.
- [Republic Act No. 6713](https://lawphil.net/statutes/repacts/ra1989/ra_6713_1989.html), Code of Conduct and Ethical Standards for Public Officials and Employees (1989), Secs. 4, 5(a), 7(b) and 11.
- [Republic Act No. 7160](https://lawphil.net/statutes/repacts/ra1991/ra_7160_1991.html), Local Government Code of 1991, Sec. 18.
- [Republic Act No. 9184](https://lawphil.net/statutes/repacts/ra2003/ra_9184_2003.html), Government Procurement Reform Act (2003), repealed by [Republic Act No. 12009](https://lawphil.net/statutes/repacts/ra2024/ra_12009_2024.html), New Government Procurement Act (2024), Sec. 115.
- [Executive Order No. 292](https://lawphil.net/executive/execord/eo1987/eo_292_1987.html), Administrative Code of 1987, Book V, Sec. 59 (nepotism), as applied in *Rubenecia*.
- [DepEd Order No. 107, s. 2010](https://www.deped.gov.ph/2010/10/20/do-107-s-2010-revised-guidelines-on-the-condemnation-and-demolition-of-school-buildings/), Revised Guidelines on the Condemnation and Demolition of School Buildings.
- [DepEd Order No. 018, s. 2023](https://www.deped.gov.ph/2023/07/21/july-20-2023-do-018-s-2023-revised-multi-year-guidelines-on-the-allocation-receipt-utilization-monitoring-and-reporting-of-the-basic-education-facilities-funds-beff/), guidelines on the Basic Education Facilities Fund, item b.4.
- [DepEd Order No. 024, s. 2020](https://www.deped.gov.ph/2020/09/07/september-7-2020-do-024-s-2020-national-adoption-and-implementation-of-the-philippine-professional-standards-for-school-heads/), Philippine Professional Standards for School Heads (indicators in the practice items).

*This guide explains Supreme Court decisions for study and professional awareness. It is not legal advice; for a specific case, consult a lawyer or your Schools Division Office's legal unit.*

## The Supreme Court cases series

- [Supreme Court Cases on School Heads: A Guide for Principals](https://nash.com.ph/blog/supreme-court-cases-school-heads)
- [Can the Ombudsman Discipline a Principal? RA 4670 Cases](https://nash.com.ph/blog/ombudsman-deped-jurisdiction-principals)
- [Can a Principal Be Reassigned to Another School?](https://nash.com.ph/blog/principal-reassignment-transfer-oic-tenure)
- [Promotion Protests and Nepotism: Cases on Principals](https://nash.com.ph/blog/principal-promotion-protest-nepotism-cases)
- [Unauthorized School Fees: What Happens to the Principal?](https://nash.com.ph/blog/unauthorized-school-fees-principal-cases)
- [Can a Principal Be Jailed Over School Funds?](https://nash.com.ph/blog/principal-malversation-graft-school-funds)
- Dishonesty and Grave Misconduct: Cases on Principals (this post)
- [Oppression Cases: How Principals Must Treat Teachers](https://nash.com.ph/blog/principal-oppression-teachers-cases)
- [Harassment, Child Abuse and Hazing: Cases on School Heads](https://nash.com.ph/blog/school-head-harassment-child-abuse-hazing-cases)
- [Is a Principal Liable When a Pupil Is Injured?](https://nash.com.ph/blog/principal-liability-pupil-injury)
- [Can a Private School Remove Its Principal?](https://nash.com.ph/blog/private-school-principal-dismissal-cases)
- [Preventive Suspension, Appeals and Back Pay for Principals](https://nash.com.ph/blog/principal-preventive-suspension-appeal-back-pay)

*Written by Mark Anthony Llego for NASH Reviewer. Sources: Supreme Court decisions in Rubenecia, Santos, Madriaga, Balbastro v. Junio, Sevilla, de la Cruz, Layug, Cucharo, Soliva, Dionisio and Corpuz; 2025 RACCS; RA 6713; RA 7160; RA 12009; DepEd Order No. 107, s. 2010. Charts may be reused only with written permission from support@nash.com.ph.*

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© 2026 Mark Anthony Llego, NASH Reviewer. All rights reserved. You may quote up to 100 words from this article with the author's name, its title and a link. In research, cite it as: Llego, M. A. (2026, October 31). *Dishonesty and Grave Misconduct: Cases on Principals*. NASH Reviewer. https://nash.com.ph/blog/principal-dishonesty-grave-misconduct-cases. Any other reuse of the article, its charts or its data needs written permission: email support@nash.com.ph. Terms of Service: https://nash.com.ph/terms#website-content-and-data