A Department of Education (DepEd) school head must keep the ethical standards of Republic Act (RA) No. 6713, the Code of Conduct and Ethical Standards for Public Officials and Employees, and run the internal controls that protect school funds and property. Fraud red flags show when those controls fail.
Below are the law’s norms and prohibited acts with school examples, a decision method worked through on three school dilemmas, and a routine for internal control. For teachers preparing for the National Assessment for School Heads (NASH, formerly the National Qualifying Examination for School Heads or NQESH) and for new school heads, the topic falls under strands 2.2, 1.3, 4.2 and 5.1 of the Philippine Professional Standards for School Heads (PPSSH) in DepEd Order No. 024, s. 2020. The rules on allowable expenses, cash advances and liquidation of Maintenance and Other Operating Expenses (MOOE) are in the guide to DepEd school MOOE. This post covers the conduct and the controls around them.
Key points
- RA 6713 applies to every school head and teacher. Section 4 sets eight norms of conduct, from commitment to public interest to simple living. Section 7 makes four groups of acts unlawful: a financial interest in transactions your office approves, certain outside work, misuse of confidential information, and soliciting or accepting gifts.
- A small, unsolicited token is not a prohibited gift, but anything given for a favor is. The law excludes “an unsolicited gift of nominal or insignificant value not given in anticipation of, or in exchange for, a favor”. The Civil Service Commission’s implementing rules judge a gift by its value, the relationship between giver and receiver, and the motivation. They set no peso limit.
- Most hard cases are temptations, not dilemmas. When a law or DepEd order already answers the question, the task is to follow it well. A true dilemma puts two legitimate duties in conflict. For those, check the law first, then weigh the options with the ethical approaches of the Markkula Center for Applied Ethics.
- Internal control is the school head’s duty, not only the bookkeeper’s. Presidential Decree (PD) No. 1445 makes the head of agency responsible for internal control, and RA 9155 gives the school head the management of the school’s resources. The five components are control environment, risk assessment, control activities, information and communication, and monitoring.
- Segregation of duties works even in a small school. The person who buys should not also receive, record and count the goods. Where staff are few, rotation, second signatures and unannounced counts by someone else reduce the risk.
- Negligence can be enough for liability. Under Article 217 of the Revised Penal Code, as amended by RA 10951, an accountable officer who through negligence permits another person to take public funds or property commits malversation. PD 1445 also makes the custodian liable for losses caused by negligence.
Why ethics is part of a school head’s job
RA 6713 begins with a policy that applies to every public servant, from a Teacher I to a regional director. Section 2 says public officials and employees “shall at all times be accountable to the people”. They must discharge their duties “with utmost responsibility, integrity, competence, and loyalty” and “uphold public interest over personal interest”.
A school head carries that duty with more authority than most teachers. RA 9155, the Governance of Basic Education Act of 2001, gives the school head the task of “Administering and managing all personnel, physical and fiscal resources of the school”. The school head approves purchases, accepts donations, signs records and supervises the people who hold cash and property. With each signature, the school head either keeps or loses public trust.
The PPSSH says the same thing in its own terms. One of its guiding principles is that the standards highlight “the importance of accountability and transparency of school heads”. The booklet explains that “the decisions and actions of school heads are open to public scrutiny and the public has a right to access information”. In Domain 2, school heads “should provide support in establishing a culture of transparency and accountability in the continuous delivery of basic education services”.
DepEd’s current orders tie school conduct to the same law. DepEd Order No. 006, s. 2026 requires a Standardized Code of Conduct for school personnel. Under it, personnel “Uphold professionalism and ethics per RA No. 6713” and DepEd Order No. 049, s. 2022. That 2022 order asks DepEd employees to “Refrain from engaging in any activity or any relationship that may impair one’s ability in making objective decisions”.
Ethics and internal control work together. Ethics guides the school head’s own choices. Internal control makes honest work the normal routine for everyone and finds errors early. Good people with weak controls still lose money to errors and theft, and strong controls fail when the school head ignores them.
RA 6713 norms of conduct, with school examples
Section 4(A) of RA 6713 lists eight standards of personal conduct. The table quotes key words from each one and shows what it looks like in a public school.
| Norm (Section 4(A)) | Key words in the law | In a school |
|---|---|---|
| (a) Commitment to public interest | Resources “must be employed and used efficiently, effectively, honestly and economically, particularly to avoid wastage in public funds and revenues” | Buy what the School Improvement Plan needs, at a fair price, and put it to use. New equipment should not stay in boxes while classes need it. |
| (b) Professionalism | Officials “shall endeavor to discourage wrong perceptions of their roles as dispensers or peddlers of undue patronage” | Show teachers and parents that loads, honors and supplies follow rules, not personal favor. |
| (c) Justness and sincerity | Officials “shall not discriminate against anyone, especially the poor and the underprivileged” and shall not extend “undue favors on account of their office to their relatives” | Serve learners from poor families without extra demands. Do not give a relative an easier load, a better room or a supply order. |
| (d) Political neutrality | Service “without unfair discrimination and regardless of party affiliation or preference” | Treat requests from barangay officials of every party alike, and keep partisan activity out of school events. |
| (e) Responsiveness to the public | “ensure openness of information” and “avoid red tape” | Answer parents’ letters on time, explain requirements in plain language, and post school fund reports. |
| (f) Nationalism and patriotism | “promote the use of locally produced goods, resources and technology” | Where the procurement rules allow a choice, consider local products and materials. |
| (g) Commitment to democracy | “maintain the principle of public accountability” | Let the School Governance Council and the Parent-Teacher Association (PTA) see and question school plans and reports. |
| (h) Simple living | “lead modest lives appropriate to their positions and income” | Live within your salary. Do not let suppliers or parents pay for your celebrations or travel. |
Section 5 adds practical duties. Officials must reply to letters from the public within 15 working days, stating the action taken. Public documents must be “accessible to, and readily available for inspection by, the public within reasonable working hours”.
Prohibited acts under RA 6713 Section 7
Section 7 declares four groups of acts unlawful for every public official and employee. The table shows each one with a school example.
| Prohibited act | What the law says | School example |
|---|---|---|
| 7(a) Financial and material interest | No “financial or material interest in any transaction requiring the approval of their office” | The school head’s spouse owns the store that supplies the school’s bond paper, and the school head approves each purchase. |
| 7(b) Outside employment and private practice | No private practice of a profession unless the Constitution or law allows it, and only if it “will not conflict or tend to conflict with their official functions” | A teacher charges a fee to tutor learners in her own class. She also grades them, so the private work can conflict with her duty to grade fairly. |
| 7(c) Confidential information | No use or disclosure of “confidential or classified information officially known to them by reason of their office” to further private interests or give someone an undue advantage | A teacher shows a test to a parent before it is given. A canvasser tells one supplier what the other suppliers quoted. |
| 7(d) Gifts | No soliciting or accepting “any gift, gratuity, favor, entertainment, loan or anything of monetary value” connected with official duties or with transactions the office affects | A supplier pays for the faculty’s Christmas party. A parent offers cash while the honors list is being decided. |
The rules in Section 7(b) continue for one year after a person leaves public office, with one difference for private practice under 7(b)(2): after leaving, the one-year bar applies only to practice “in connection with any matter before the office he used to be with”. Under Section 11, a violation can lead to administrative penalties up to removal from the service. Violations of Sections 7, 8 or 9 can also be punished in court with imprisonment of up to five years, a fine of up to PHP 5,000, or both.
In Office of the Ombudsman v. Santos (2006), managing a private school while serving as a public school principal broke RA 6713; the principal’s dismissal rested on dishonesty and grave misconduct found in the same case. See Dishonesty and Grave Misconduct: Cases on Principals.
Gifts from parents, suppliers and partners
RA 6713 does not ban every gift. Its definition of a gift excludes “an unsolicited gift of nominal or insignificant value not given in anticipation of, or in exchange for, a favor”. The occasion does not change the rule. The law covers gifts received “even on the occasion of a family celebration or national festivity like Christmas”. Such a gift is prohibited if its value is “neither nominal nor insignificant” or if it is given in anticipation of, or in exchange for, a favor.
The Civil Service Commission (CSC) administers the law and adopted its implementing rules on April 21, 1989. Rule X states: “The propriety or impropriety of the foregoing shall be determined by its value, kinship or relationship between giver and receiver and the motivation”. Whether a gift is nominal “will depend on the circumstances of each case”. The rules name the factors: the official’s salary, how often gifts are given, the expectation of benefits, and other similar factors.
The rules also exclude “Nominal donations from persons with no regular, pending, or expected transactions” with the office. A supplier with a pending quotation does not meet that condition. RA 3019, the Anti-Graft and Corrupt Practices Act, adds a criminal prohibition. Its Section 3(b) punishes “requesting or receiving any gift, present, share, percentage, or benefit” in connection with a government contract or transaction in which the officer must take part. Its Section 14 excepts “Unsolicited gifts or presents of small or insignificant value offered or given as a mere ordinary token of gratitude or friendship according to local customs or usage”.
Before you accept anything, ask four questions:
- Did I or my staff ask for it?
- Is its value small for a person of my salary?
- Does the giver have a pending or expected transaction with the school, such as enrollment, grades, honors, a delivery or a payment?
- Would I be comfortable if every parent and supplier knew about it?
| Situation | How the rules read | What the school head does |
|---|---|---|
| A class’s parents give their adviser a card and a homemade cake on World Teachers’ Day, after grades are released | Unsolicited, small, and not tied to a favor | Accept with thanks and share it with the faculty |
| A supplier sends the school head a large holiday basket while its delivery waits for inspection | A pending transaction, and a value that may be more than nominal | Return it with a polite letter, and keep a copy |
| A parent offers cash “for snacks” while her complaint about her child’s grade is pending | Given in anticipation of a favor | Decline, explain the grade review process, and note the offer in writing |
| PTA officers propose collecting money from learners to buy gifts for teachers | DepEd’s no-collection policy prohibits collecting contributions from learners and teachers | Stop the collection and explain the policy to the PTA |
| A company with no dealings with the school offers ten electric fans for classrooms | A donation to the school, not a personal gift | Accept it for the school if it serves a purpose RA 9155 allows, record it as school property, and report it |
On the fourth case, DepEd Memorandum No. 041, s. 2024 reiterates the prohibition in RA 4206, as amended. It covers the collection of contributions “in any form whatsoever, by any person for any project or purpose, whether voluntary or otherwise”. The memorandum also reminds DepEd personnel to “refrain from unwarranted solicitations and collection of contributions”.
The fifth case is different because the gift goes to the school. RA 9155 allows school heads to accept donations “for the purpose of upgrading teachers’/learning facilitators’ competencies, improving and expanding school facilities and providing instructional materials and equipment”. Such donations “must be reported to the appropriate district supervisors and division superintendents”. The Administrative Code of 1987 treats such donations as public property. Its Section 42 says that all money and property “officially received by a public officer in any capacity or upon any occasion” must be “accounted for as government funds and government property”. The guide to RA 9155 school head duties explains the donation clause.
Relatives, conflicts of interest and use of school property
RA 6713 defines relatives as persons “within the fourth civil degree of consanguinity or affinity, including bilas, inso and balae”. Section 4(c) bars undue favors to them. In a school, this covers teaching loads, class assignments, nominations for training, and the choice of suppliers and service providers.
Under Section 3(i), a conflict of interest arises when an official’s business interest “may be opposed to or affected by the faithful performance of official duty”. Section 9 then requires the official to resign from the business or divest the interest within the periods the law sets. RA 3019 Section 3(e) also punishes “giving any private party any unwarranted benefits, advantage or preference” through “manifest partiality, evident bad faith or gross inexcusable negligence”.
Procurement law is stricter on relatives. RA 12009 is the New Government Procurement Act of 2024. Under its Section 81, bidders must swear that they are not related within the third civil degree to the officials who handle the procurement. Such a relationship automatically disqualifies the bidder, even if the related official inhibits from the process.
School property belongs to the public. PD 1445, the Government Auditing Code of the Philippines, states that “Government funds or property shall be spent or used solely for public purposes”. A school head should not use the school’s vehicle, sound system, projector, photocopier or rooms for private business or family events. Any use by outside groups should be approved under DepEd rules and recorded.
The SALN and disclosure of relatives
Section 8 requires all public officials and employees to file a sworn Statement of Assets, Liabilities and Net Worth (SALN) and a Disclosure of Business Interests and Financial Connections. The exceptions are those who serve in an honorary capacity, laborers, and casual or temporary workers. The statements include the spouse and unmarried children under 18 living in the household.
The law sets three filing times: within 30 days after assuming office, “on or before April 30, of every year thereafter”, and within 30 days after leaving the service. Section 8(B) also requires every official to disclose relatives in government in the form the CSC prescribes. A school head files a truthful SALN on time and reminds staff of the deadline.
Ethical dilemmas and temptations: how to tell them apart
Rushworth Kidder, in How Good People Make Tough Choices (1995), separated “right versus wrong” choices from “right versus right” choices. A school head meets both kinds, and they need different responses.
A temptation is a choice between right and wrong. The law, a DepEd order or a professional code already gives the answer. The difficulty is that the right action costs something: a friendship, money, comfort, or a parent’s goodwill. A true dilemma is a choice between two rights. Two duties you owe are in real conflict, and any option gives up something of value.
Three questions sort them:
- Does a law, rule or DepEd order already answer the question? If yes, it is not a dilemma. Follow the rule and plan how to do it well.
- Is the only difficulty that the right action is costly or unpopular? If yes, it is a temptation.
- Do two legitimate duties call for different actions, with no rule to settle them? If yes, it is a dilemma. Use the method in the next section.
| Situation | Type | Why |
|---|---|---|
| A canvasser suggests splitting a purchase into small orders so that each stays under a procurement limit | Temptation | RA 12009 Section 39 prohibits splitting government contracts to evade the law’s requirements |
| A supplier offers the school head a “rebate” of 10% of each payment | Temptation | RA 6713 Section 7(d) and RA 3019 Section 3(b) prohibit it |
| A teacher asks the school head to sign a daily time record (DTR) that hides two weeks of late arrivals while she cared for a sick child | Temptation, with a real problem behind it | The record must be true. The real question is how to support the teacher within the leave and attendance rules |
| Two qualified teachers ask for the one training slot the division gave the school | Dilemma | Fairness to the senior teacher and the needs of the learners lead to different choices |
| The property custodian asks to pay quietly for missing equipment so that no report is made | Looks like a dilemma, but the law decides it | PD 1445 sets the duty to report. The only open question is how to help the custodian |
A step-by-step method for ethical decisions
The Markkula Center for Applied Ethics at Santa Clara University publishes “A Framework for Ethical Decision Making”. Its steps are to identify the ethical issues, get the facts, evaluate alternative actions, choose an option and test it, and then implement the decision and reflect on the outcome. The method below adapts those steps to a public school and adds a check of the law near the start.
- Name the issue. Write the question in one sentence: “Should I do A or B?” If someone is pressing you, ask for time. Few school decisions must be made within the hour.
- Get the facts. Read the documents yourself. List who is affected: learners first, then staff, parents and the public. Separate what you know from what you were told.
- Check the law and DepEd rules. Look at RA 6713, RA 3019, PD 1445, the DepEd orders on the subject, and the teachers’ professional code of ethics. If a rule answers the question, the case is a temptation, so follow the rule.
- List at least three options. Most people see only “yes” or “no”. A third option, such as “yes, with conditions” or “not now, but next quarter”, is often the best one.
- Test each option with the ethical approaches. Use the questions in the table below.
- Choose, then test the choice. Apply the publicity, consistency and record tests described below.
- Act, record and explain. Write a short note of the decision and the reasons. Tell the people affected why you decided as you did.
- Reflect afterwards. Ask what you learned, and whether a rule or control should change so that the problem does not return.
Step 6 uses three quick tests.
- Publicity test. The Markkula framework asks what someone you respect, or a public audience, would say if you told them which option you chose. For a school head, that audience is the faculty, the PTA and the division.
- Consistency test. Would you decide the same way for any teacher, parent or supplier in the same position, and next year too?
- Record test. Could you write the decision and its reasons in the minutes, on the voucher or on the transparency board without changing any facts?
The five ethical approaches
The Markkula framework calls its approaches “lenses”. The five long-standing ones are below, with questions paraphrased from the framework. The Center’s revision of November 5, 2021 added a sixth lens, care ethics, which asks you to account for the relationships, concerns and feelings of everyone involved.
| Approach | The question it asks | School example |
|---|---|---|
| Utilitarian | Which option does the most good and the least harm for everyone affected? | Spending the repair budget on the leaking roof over the Grade 1 rooms, which serve the most learners |
| Rights | Which option best respects the rights of everyone with a stake? | Letting a teacher accused of an error see the evidence and explain before any action |
| Justice or fairness | Which option treats people fairly, giving each what they are due by a defensible standard such as merit or need? | Choosing who attends a training by criteria announced in advance |
| Common good | Which option best serves the whole community, not only some members? | Keeping the library open to all learners instead of reserving it for a contest team |
| Virtue | Which option makes me act as the person I want to be? | Returning a supplier’s gift even though no one would find out |
| Care ethics (added in 2021) | Which option takes account of the relationships, concerns and feelings of everyone involved? | Helping a struggling teacher find support while keeping the records true |
The approaches can lead to different answers. When they agree, the decision is usually clear. When they disagree, the three tests and an honest record help you choose and explain the choice.
Three school dilemmas worked through
Dilemma 1: One training slot, two qualified teachers
Facts. The division gives the school one slot in a five-day reading intervention training for “Grade 3 teachers”. Two Grade 3 teachers apply. One has 22 years of service and has never attended a division training. The other has four years of service and handles the section with the most learners reading below grade level.
Law check. The division memorandum sets no other criterion, and no law decides who should go. This is a true dilemma.
Options. (a) Send the senior teacher as recognition of her service. (b) Send the teacher whose learners need the training most. (c) Send the newer teacher, ask her to share the training with the other Grade 3 teachers afterwards, and keep a written rotation for future slots.
Approaches. The utilitarian and common good approaches favor (b) or (c), because more struggling readers benefit. Justice can support either teacher: seniority is a defensible standard, but the training’s purpose makes need the more relevant one. Care ethics warns that the senior teacher may feel overlooked once again.
Decision. Option (c). Before announcing the choice, the school head explains the criterion to both teachers: the training’s purpose and the learners’ needs. The newer teacher leads a learning action cell session after the training. The school head starts a training record so that the senior teacher gets the next suitable slot.
Tests. The faculty can accept a reason tied to learners (publicity). The same criterion will apply next time (consistency). The decision and its reason fit in the school’s training record (record).
Dilemma 2: A supplier offers the school a printer
Facts. A bookstore supplied the school’s bond paper last month and has quoted again for next quarter. Its owner offers to donate a new printer to the school. The school needs one to print learning materials.
Law check. The printer would go to the school, not to the school head, and RA 9155 allows donations of equipment. But the store has pending and expected transactions with the school, so the exclusion for nominal donations does not apply, and a printer is not nominal. The gift rules look at the giver’s dealings with the office and the motivation. The law does not give a simple yes, so the school head must weigh the options.
Options. (a) Accept now. (b) Decline. (c) Thank the owner in writing and decline while the store is a current supplier. Then look for a printer through the school’s plan, the Local School Board or a donor with no dealings with the school.
Approaches. The utilitarian approach favors (a), because learners get printed materials sooner. Justice favors declining, because the other stores competing in the canvass would face a supplier that gave the school a gift. Virtue and the common good also favor declining. A school that takes gifts from its suppliers teaches the community that business with the school can be bought.
Decision. Option (c). The school head keeps a copy of the letter and lists the printer as a need in the school’s plan.
Tests. Competing suppliers would see the gift as unfair (publicity). The school would not accept a similar gift from every bidder (consistency). The polite refusal letter can be filed and shown to an auditor (record).
Dilemma 3: Missing tablets and an offer to pay quietly
Facts. During a count, the property custodian finds that two learner tablets are missing from the information and communications technology (ICT) room. She has served the school for 15 years and is a single parent. She is afraid of a case and offers to pay for the tablets from her salary “so there is no report”.
Law check. PD 1445 Section 105 makes an officer accountable for government property liable “for all losses, damages, or deterioration occasioned by negligence in the keeping or use of the property”. Section 73 requires the accountable officer to “immediately notify” the Commission on Audit (COA) or its auditor when property is lost through theft or other casualty. The officer must then apply for relief within 30 days. An officer who does not do so “shall not be relieved of liability”. Section 104 requires the head of agency to supervise accountable officers with “the diligence of a good father of a family”. The law requires a report, so the only open question is how to treat the custodian.
Options. (a) Accept the quiet payment. (b) Report the loss and leave the custodian to face it alone. (c) Report the loss at once, help the custodian document what happened, and fix the control that failed.
Approaches. Care ethics seems to favor (a). But (a) hides a possible theft, leaves the thief free, and takes away the custodian’s chance to be relieved of liability if she was not negligent. Rights and justice favor (c): she has the right to explain, and the public has the right to an honest record. The common good also favors (c), because the next loss can be prevented only if the cause is found.
Decision. Option (c). The school head secures the room and sends a written report to the Schools Division Office (SDO). If theft is suspected, the school head reports it to the police. The school head helps the custodian notify the auditor and prepare the application for relief with evidence. The school head then adds three controls: a key log for the ICT room, issue of tablets by class against signed receipts, and a monthly count by a second person.
Tests. The quiet payment fails the record test, because it cannot be written down truthfully. Option (c) passes all three tests.
Internal control in a school: the five components
PD 1445 Section 123 defines internal control as the plan of organization and the coordinated methods an agency adopts for three purposes. They safeguard its assets, check the accuracy and reliability of its accounting data, and encourage adherence to managerial policies. Section 124 states: “It shall be the direct responsibility of the agency head to install, implement, and monitor a sound system of internal control”. Within a school, RA 9155 gives the management of resources to the school head, so the school head runs these controls every day.
The Department of Budget and Management (DBM) issued the National Guidelines on Internal Control Systems (NGICS) through Circular Letter No. 2008-8. The NGICS sets five general objectives for internal control in the public sector:
- Safeguard assets.
- Check the accuracy and reliability of accounting data.
- Ensure economical, efficient and effective operations.
- Comply with laws and regulations.
- Adhere to managerial policies.
The NGICS also names five interrelated components. The same five appear in the Internal Control–Integrated Framework of the Committee of Sponsoring Organizations of the Treadway Commission (COSO), first issued in 1992 and updated in 2013. COSO calls the fifth component “monitoring activities”. The first of its 17 principles is that the organization “Demonstrates commitment to integrity and ethical values”, and another is that it “Assesses fraud risk”.
| Component | What it means | School example |
|---|---|---|
| Control environment | The standards, structure and example that shape how people behave | The school head issues written designations for the property custodian, canvasser and inspector, explains the gift rules to staff and suppliers, and follows them personally |
| Risk assessment | Identifying what could go wrong, and how likely and serious it is | Listing the school’s risks: cash kept overnight, deliveries accepted without counting, tablets in an unlocked room, registers that still list learners who have left |
| Control activities | The policies and procedures that reduce those risks | Approval before purchase, different people for buying and receiving, locked storage, counts compared with records, and complete documents before payment |
| Information and communication | Records and reports that reach the people who need them | Current stock and property records, a monthly cash summary, and a transparency board that parents can read |
| Monitoring | Checking that the controls work, and fixing those that do not | A surprise cash count, a periodic property count, and a review of last year’s audit findings |
The transparency board is a control that DepEd already requires. DepEd Order No. 008, s. 2019 directs school heads to post the sources, intended use and actual use of school funds on a Transparency Board. The board “must be publicly accessible and must be updated every three (3) months”. The order also directs school heads to present the sources and uses of school funds to the faculty, the PTA, the School Governance Council and local partners through the School Report Card.
Segregation of duties in a small school
The NGICS states: “Key duties and responsibilities need to be divided or segregated among different people to reduce the risk of error or fraud”. It names the duties to separate: processing, reviewing, recording, custody, and approval or authorization of transactions.
No single person should be able to start a transaction, approve it, handle the money or goods, record it and check it. When one person does everything, an error can go unseen and a theft can be hidden.
| Duty | Who usually does it | Who should not also do it |
|---|---|---|
| State the need | Teacher or other end user | Not applicable |
| Approve | School head | The person who will buy |
| Canvass or buy | Designated teacher or administrative officer | The person who receives and inspects |
| Receive and inspect | Inspector or inspection team | The person who bought |
| Hold cash or pay | Bonded disbursing officer or cash advance holder | The person who records and reconciles |
| Record stock, property and cash | Property custodian or bookkeeper | The person who holds the items or the cash |
| Count and review | A teacher outside the transaction, or the school head | The person whose records are counted |
PD 1445 Section 101 adds that “Every accountable officer shall be properly bonded in accordance with law”.
Many small schools have a teacher-in-charge and three to six teachers, so full separation is not possible. Use these compensating controls:
- Separate at least the buyer from the receiver, and the cash holder from the person who counts the cash.
- Rotate canvass and inspection duties among teachers each quarter.
- Require two signatures on delivery documents and cash counts.
- Have someone outside the transaction count cash and property on dates that are not announced.
- Post fund reports on the transparency board and present them to the PTA and the School Governance Council, so that people outside the transactions can ask questions.
- Ask the SDO’s finance and supply staff for guidance when the school cannot separate a duty.
Property custody and inventory in a school
Every person who holds government property is accountable for it. PD 1445 Section 101 covers every officer whose duties involve “the possession or custody of government funds or property”. That officer is accountable for them “and for the safekeeping thereof in conformity with law”. Section 105 makes that officer liable for losses of the property caused by negligence, “whether or not it be at the time in his actual custody”.
Good custody practice in a school follows six steps:
- Record every item on arrival, including donated items, with its description, serial number, cost or appraised value, and source.
- Issue each item to a named person who signs for it, and update the record whenever the item moves to another person.
- Lock stock rooms and ICT rooms, keep a list of who holds keys, and log who enters.
- Count property and supplies periodically and compare the count with the records. The NGICS says: “Periodic physical count and inspection of assets and facilities should be made and compared with the records to address the risk of error, fraud, misuse or unauthorized alteration”.
- Report losses at once. PD 1445 Section 73 requires immediate notice to COA or the auditor when funds or property are lost through fire, theft or other casualty. The accountable officer must also apply for relief within 30 days.
- Do not dispose of property on your own. Unserviceable property is disposed of under the Revised Manual on the Disposal of Government Properties in COA-DBM Joint Circular No. 2024-1 of January 30, 2024, which works through a Disposal Committee.
The PPSSH Domain 2 guide shows the condition of public school buildings and equipment that these records describe.
Cash handling at school level
Cash is the asset most easily lost. PD 1445 Section 4 sets the principles behind these habits, including that “Claims against government funds shall be supported with complete documentation”.
- Keep as little cash in school as possible, in a locked place, with one named custodian.
- Record and receipt every collection on the day it is received, and turn it over or deposit it as the rules require.
- Never mix school money with personal money, and never lend school cash to anyone, even for a day.
- Pay only against complete documents, and never sign blank vouchers, checks or forms.
- Count cash with a second person present, and hold a surprise count from time to time.
- Do not collect contributions from learners or teachers, under DepEd Memorandum No. 041, s. 2024.
- For cash advances and liquidation of school MOOE, follow the DepEd school MOOE guide.
Malversation: when negligence is enough
Article 217 of the Revised Penal Code, as amended by RA 10951 in 2017, punishes an accountable public officer who takes or misappropriates public funds or property. It also punishes an officer who “shall consent, through abandonment or negligence, shall permit any other person to take such public funds or property”. The article adds that failure to produce public funds or property on demand “shall be prima facie evidence that he has put such missing funds or property to personal uses”.
For a school head, this has two consequences. If you cannot produce funds you are accountable for when a duly authorized officer demands them, the law presumes that you put them to personal use, until you explain the shortage. If another person took the money because you were careless, you can still be liable. Leaving a cash box unlocked, or letting staff hold funds without counts, is a legal risk as well as an ethical one.
For the Supreme Court cases on principals and malversation, graft and procurement, see Can a Principal Be Jailed Over School Funds?.
Fraud red flags in vouchers, receipts, canvasses and attendance records
A red flag is a warning sign that calls for a closer look. It is not proof of fraud. Many red flags have honest explanations, such as a small town with only two suppliers. The school head’s task is to notice them, ask questions and check the documents.
Red flags in canvasses and purchases
- Three quotations in the same handwriting, format, paper or ink, or from suppliers who share an address, phone number or owner
- The same supplier wins every time, often by a small margin
- Specifications written so that only one brand or one store can meet them
- Several small purchases of the same item within a short period, each just under an approval or procurement limit
- Purchases that do not appear in the school’s procurement plan
On split purchases, RA 12009 Section 39 prohibits “dividing or breaking up of contracts into smaller quantities and amounts” for the purpose of evading the law. Section 92 makes “Splitting of contracts which exceed procedural purchase limits and competitive bidding” a ground for administrative liability.
Red flags in vouchers and payments
- The same invoice paid twice, or amounts that are corrected, erased or written over
- Payees who are employees or their relatives, or names that also appear as suppliers
- Payments made before the goods were delivered and inspected
- Missing supporting documents, or photocopies offered without explanation
- Round amounts for items that are usually priced in odd amounts
Red flags in receipts and delivery documents
- Receipts from one supplier with consecutive numbers across several months, which suggests the supplier rarely issues receipts to anyone else or wrote them all at one time
- Receipts dated before the purchase request, or from a store that does not sell the item
- Delivery and inspection documents signed by the person who bought the items
- Delivery documents signed before the goods arrived, or quantities that nobody counted
Red flags in attendance and enrollment records
- DTRs with the same arrival and departure times every day, written in the same ink for a whole month
- A DTR that shows a teacher present on a day of approved leave, official travel or training
- DTRs signed by the supervisor before the month ends
- Learners who still appear in School Form 2 (SF2), the Learner Daily Attendance Report, months after they moved away
- Lists for feeding or reading programs that name more learners than the class registers
These records matter because pay and resources depend on them. A false DTR pays for work not done. False enrollment and attendance records can draw resources meant for learners who are not there.
For property, look for items that cannot be found during a count and serial numbers that do not match the records. Equipment listed as “under repair” for months with no repair documents is another warning sign.
What to do when you find a problem
- Secure the records and assets. Lock the room or cash box, keep the original documents, and make copies. Do not let anyone change the records.
- Check the facts quietly. Compare the documents, count again with a witness, and ask the person concerned to explain in writing.
- Separate error from possible wrongdoing. Correct an honest error, record the correction, and fix the control that allowed it.
- Report possible wrongdoing in writing through proper channels. Report to the SDO, and notify the COA auditor of losses of funds or property as PD 1445 Section 73 requires. DepEd Order No. 049, s. 2022 tells personnel to “Raise issues and concerns regarding basic education via formal and appropriate DepEd channels”.
- Leave formal charges to the proper body. RA 4670, the Magna Carta for Public School Teachers, gives the first hearing of administrative charges against a teacher to a committee. The division’s school superintendent or an authorized representative chairs it. The teacher has the right to be told the charges in writing, to see the evidence and to be defended. The law adds: “No publicity shall be given to any disciplinary action being taken against a teacher during the pendency of his case”. The committee is not the only body that can hear such charges. In Office of the Ombudsman v. Medrano (2008), the Supreme Court held that the Ombudsman’s disciplinary authority over a public school teacher “is not an exclusive power but is concurrent with the proper committee of the DepEd”, though it added that the complaint “should have been referred” to that committee. A teacher or school head who wants the DepEd committee to hear the case must object early. See Can the Ombudsman Discipline a Principal?. If the person charged is preventively suspended, Preventive Suspension, Appeals and Back Pay for Principals explains the limits and when pay is restored. Who decides the charge, and what you do while it is pending, are in Who Disciplines DepEd Teachers and School Heads? and What a School Head Does When a Complaint Arrives.
- If a superior directs an irregular payment, object in writing first. Under PD 1445 Section 106, an accountable officer who follows such a direction remains liable. The exception applies only if, “prior to that act, he notified the superior officer in writing of the illegality of the payment, application, or disposition”.
- Protect the person who reported. Keep the reporter’s identity confidential as far as the process allows. RA 6713 Section 12 directs the Ombudsman to “take steps to protect citizens who denounce acts or omissions of public officials and employees which are in violation of this Act”.
- Fix the control. Record what failed and change the procedure so that the same problem cannot happen again.
What the school head does: an ethics and internal control routine
| When | What the school head does | With whom | Document |
|---|---|---|---|
| Start of the school year | Issue written designations that separate buying, receiving, custody and recording. Brief staff on RA 6713, DepEd Order No. 049, s. 2022 and the school code of conduct. Tell suppliers and the PTA the gift and no-collection rules. | Faculty, PTA, suppliers | Designation orders, orientation record |
| Each purchase | Approve the request against the plan, check the quotations, make sure a different person inspects the delivery, and sign only complete documents | Canvasser, inspector, custodian | Purchase request, quotations, inspection report, voucher |
| Each month | Review the cash records and count the cash with a witness. Review DTRs and learner attendance. | Cash custodian, advisers | Cash records, DTRs, SF2 |
| Every three months | Update the transparency board on the sources and uses of school funds | Bookkeeper or administrative officer | Transparency board posting |
| When presenting the School Report Card | Present the sources and uses of school funds to the faculty, PTA, School Governance Council and partners | School planning team | School Report Card |
| At least once a year | Lead a physical count of property and supplies, and file your SALN by April 30 | Property custodian, a counting team | Count report, SALN |
| When a problem appears | Follow the eight steps above | SDO, COA auditor | Written report |
PPSSH strands and Career Stage 1 indicators
This topic draws on four strands of the PPSSH. The indicator texts below are quoted from DepEd Order No. 024, s. 2020.
| Strand | Career Stage 1 indicator | How this guide applies it |
|---|---|---|
| 2.2 Financial management | 2.2.1 Demonstrate knowledge and understanding of policies, guidelines and issuances in managing finances such as allocation, procurement, disbursement and liquidation aligned with the school plan. | The controls around procurement and disbursement: segregation of duties, complete documents, and red flags in canvasses and vouchers |
| 1.3 Policy implementation and review | 1.3.1 Demonstrate knowledge and understanding of policy implementation and review to ensure that school operations are consistent with national and local laws, regulations and issuances. | RA 6713, RA 3019, PD 1445 and the DepEd orders that set the limits of a school head’s conduct |
| 4.2 Professional reflection and learning | 4.2.1 Demonstrate understanding of how professional reflection and learning can be used in improving practice. | The last step of the decision method: reflecting on each hard case and changing practice |
| 5.1 Management of diverse relationships | 5.1.1 Demonstrate skills in dealing with authorities, colleagues, parents and other stakeholders to encourage an enabling and supportive environment for learners. | Declining gifts and favors from parents and suppliers while keeping their support for learners |
Two more indicators connect to this guide. Indicator 2.3.1 covers “acquisition, recording, utilization, repair and maintenance, storage, and disposal” of school facilities and equipment, which is where property custody belongs. At Career Stage 4, indicator 2.2.4 asks school heads to “Create and implement a checking mechanism to sustain efficient and effective management of finances”. The routine above is a first step toward that. The PPSSH guide lists every strand and indicator.
Practice: how the NASH may test this
DepEd Memorandum No. 069, s. 2025 says the NASH covers “conceptual and situational critical thinking questions” aligned with the PPSSH and built on the SOLO taxonomy. Items in this area are likely to describe a gift, a request for a favor, or a weak control, and ask for the best action. The best answer usually follows the law and also keeps the relationship or the service to learners. Weaker answers break a rule to avoid conflict, or apply the rule without fixing the cause. The three items below are original practice items, not actual NASH items.
Question 1
Indicator 1.3.1, Policy implementation and review. Career Stage 1, Situational, Moderate.
In mid-December, the owner of a store that supplies the school’s office and cleaning materials sends the school head a large holiday food basket. The store has submitted a quotation for next quarter’s supplies, and the canvass is still open. What should the school head do?
- A. Accept the basket and share it with the faculty at the Christmas party, since it arrived during a national festivity and benefits the whole staff equally.
- B. Accept the basket but give the canvass to another teacher, so that the gift cannot influence the choice of supplier for the next quarter.
- C. Return the basket with a courteous letter that explains the rule on gifts from parties with pending transactions, and keep a copy on file.
- D. Keep the basket unopened in the office until the canvass closes, then decide whether to accept it depending on which store wins.
Answer and explanation
Best answer: C. Points: A = 1, B = 2, C = 3, D = 0.
- A (1 point, Unistructural). It notices the occasion but misreads the law. RA 6713 covers gifts received “even on the occasion of a family celebration or national festivity like Christmas” when they are more than nominal or given in anticipation of a favor.
- B (2 points, Multistructural). It sees the conflict and separates the canvass from the gift. However, the gift is still accepted from a party with a pending transaction, and the store’s other dealings with the school continue.
- C (3 points, Relational). It applies the rule, keeps the relationship courteous, and creates a record. The store remains free to compete, and the school head’s decision can be shown to anyone who asks.
- D (0 points, Prestructural). Making acceptance depend on who wins turns the gift into the kind of exchange for a favor that the law prohibits.
Why. Section 7(d) of RA 6713 prohibits accepting anything of monetary value connected with “any transaction which may be affected by the functions of their office”. The implementing rules exclude nominal donations only from persons with “no regular, pending, or expected transactions” with the office, and this store has a pending one. Indicator 1.3.1 asks for school operations consistent with national laws. A large basket from a current bidder fails that test, while a polite written return passes it.
Indicator 1.3.1: Demonstrate knowledge and understanding of policy implementation and review to ensure that school operations are consistent with national and local laws, regulations and issuances.
Sources: Republic Act No. 6713, Sections 3 and 7(d); Rules Implementing RA 6713 (Civil Service Commission, 1989), Rule X; Republic Act No. 3019, Section 3(b).
Question 2
Indicator 2.2.1, Financial management. Career Stage 1, Situational, Moderate.
A newly designated teacher-in-charge leads an elementary school with five teachers. She learns that for two years one teacher has canvassed suppliers, bought the supplies, signed the delivery and inspection documents, and kept the stock cards. No problem has ever been reported. What is the most appropriate first step?
- A. Keep the arrangement, since no problem has been reported and the teacher knows the suppliers, and ask the teacher to submit a monthly summary of purchases.
- B. Ask the division office to audit the school’s purchases for the past two years, and make no change to the assignments until the audit is finished.
- C. Take over all canvassing and inspection personally, so that from now on the teacher-in-charge alone handles every purchase from start to finish.
- D. Reassign duties so that the buyer no longer inspects or keeps records, and have another teacher count the stocks against the cards on unannounced dates.
Answer and explanation
Best answer: D. Points: A = 0, B = 2, C = 1, D = 3.
- A (0 points, Prestructural). The absence of reported problems is not evidence that the controls work. With one person doing everything, an error or a theft would not be reported by anyone.
- B (2 points, Multistructural). It recognizes the risk and seeks a review. However, it leaves the weak arrangement in place while waiting, and a review can follow if the new counts show a problem.
- C (1 point, Unistructural). It removes the risk from the teacher but puts every duty in the hands of the approver, which repeats the same weakness.
- D (3 points, Relational). It separates buying from receiving and recording, and adds a count by someone outside the transaction. These compensating controls fit a school with only five teachers.
Why. The National Guidelines on Internal Control Systems say that key duties “need to be divided or segregated among different people to reduce the risk of error or fraud”. The duties to separate include processing, recording, custody and approval. Indicator 2.2.1 asks for knowledge of the policies on procurement and disbursement. Knowing them includes knowing that one person should not buy, receive, record and count.
Indicator 2.2.1: Demonstrate knowledge and understanding of policies, guidelines and issuances in managing finances such as allocation, procurement, disbursement and liquidation aligned with the school plan.
Sources: DBM Circular Letter No. 2008-8, National Guidelines on Internal Control Systems; Presidential Decree No. 1445, Sections 101, 104 and 124; DepEd Order No. 024, s. 2020.
Question 3
Indicator 5.1.1, Management of diverse relationships. Career Stage 1, Situational, Difficult.
A PTA officer arranged a large donation of books from local businesses last year. She now asks the school head for a copy of next week’s Grade 6 mathematics test, “so parents can help the children review”. She hints that the PTA may not support the next school project if the school refuses. What should the school head do?
- A. Give the test to all PTA officers at the same time so that no single parent gains an advantage, and ask the officers to keep it confidential.
- B. Decline to release the test, explain that it is confidential and must be fair to all learners, and offer review materials for every Grade 6 class.
- C. Decline to release the test, and stop consulting the officer on school projects, since a parent who pressures the school should lose that role.
- D. Refer the request to the Grade 6 teachers and let them decide, because writing and releasing tests are the responsibility of the classroom teachers.
Answer and explanation
Best answer: B. Points: A = 0, B = 3, C = 2, D = 1.
- A (0 points, Prestructural). Sharing the test with the officers gives their children an advantage over every other learner and discloses information the school holds in confidence.
- B (3 points, Relational). It protects the test and the fairness of grading, and it answers the parent’s real concern, which is helping the children prepare. The partnership can continue without any special favor.
- C (2 points, Multistructural). It keeps the test confidential but punishes the parent. That damages a partnership that serves learners and makes the school look as if it is retaliating.
- D (1 point, Unistructural). It passes the decision to teachers who are under the same pressure. The school head is responsible for the integrity of school records and assessments.
Why. RA 6713 Section 7(c) prohibits using or disclosing “confidential or classified information officially known to them by reason of their office” to give undue advantage to anyone. Section 4(c) asks officials to act with justness and sincerity. Indicator 5.1.1 asks for skill in dealing with parents and stakeholders “to encourage an enabling and supportive environment for learners”. Option B does that without giving up the fairness of the test to keep a donor’s support.
Indicator 5.1.1: Demonstrate skills in dealing with authorities, colleagues, parents and other stakeholders to encourage an enabling and supportive environment for learners.
Sources: Republic Act No. 6713, Sections 4(c) and 7(c); DepEd Order No. 024, s. 2020.
More items across all five domains are in the NASH practice questions with answers, and timed sets are in the NASH Reviewer assessment.
Frequently asked questions
What does RA 6713 say about accepting gifts?
RA 6713 Section 7(d) prohibits public officials and employees from soliciting or accepting any gift, favor, loan or anything of monetary value connected with their duties. The ban also covers gifts connected with transactions their office affects. The law excludes an unsolicited gift of nominal or insignificant value that is not given in anticipation of, or in exchange for, a favor. The CSC’s implementing rules judge a gift by its value, the relationship between giver and receiver, and the motivation, and they set no peso limit.
Can public school teachers accept gifts from parents on Teachers’ Day or at Christmas?
A teacher may accept a small, unsolicited token, such as a card or food, that is not given in exchange for a favor. The occasion does not change the rule: RA 6713 treats a Christmas gift as prohibited if its value is more than nominal or it is given for a favor. A teacher should decline gifts from parents whose child has a pending grade, honors or enrollment decision.
What code of conduct applies to public school teachers in the Philippines?
Public school teachers follow RA 6713, the Code of Conduct and Ethical Standards for Public Officials and Employees, like all government employees. Licensed teachers are also covered by the Code of Ethics for Professional Teachers, the code of ethical and professional standards that RA 7836 lets the Board for Professional Teachers adopt. Violating that code is a ground to suspend or revoke a teacher’s license under Section 23 of RA 7836. DepEd Order No. 049, s. 2022 adds DepEd’s own standards of professionalism, and DepEd Order No. 006, s. 2026 requires a Standardized Code of Conduct for school personnel.
What is an example of an ethical dilemma for a school principal?
A common example is choosing which of two qualified teachers attends the only training slot the division gives the school. Fairness to the senior teacher and the needs of the learners lead to different choices, and no rule decides it. The school head can settle it by announcing a criterion tied to the training’s purpose and keeping a rotation record for future slots.
What are the five components of internal control?
The five components of internal control are control environment, risk assessment, control activities, information and communication, and monitoring. They appear in the DBM’s National Guidelines on Internal Control Systems and in COSO’s Internal Control–Integrated Framework, which calls the last component monitoring activities.
More on school leadership
This post is part of a series on what a school head does under the DepEd rules in force today. The other posts, in reading order:
- RA 9155 Duties of DepEd School Heads: 12 Areas Explained
- Leadership vs Management for School Heads: Five Practices
- DepEd Revised SBM: DO 007, s. 2024 and the Self-Assessment
- DepEd School Improvement Plan (SIP): Steps, AIP and SRC
- Root Cause Analysis for the DepEd School Improvement Plan
- Organizational Diagnosis Models in Schools: 7S, SWOT, PESTLE
- Change Management in Schools: A Guide for DepEd School Heads
- DepEd ILAW Lesson Plan, DO 016, s. 2026: School Head’s Role
- DepEd Grading System, DO 015, s. 2026: School Head’s Role
- DepEd Contextualization, Localization and Indigenization
- DepEd Instructional Supervision: Observing and Coaching
- DepEd Learning Action Cell (LAC) Guidelines: DO 35, s. 2016
- DepEd PMES for Teachers: DM 089, s. 2025 for School Heads
- DepEd Enhanced ALS, Inclusive Education and Special Programs
- Human Resource Management for DepEd School Heads
- DepEd School MOOE: Allowable Expenses and Liquidation
- Leadership Styles of School Heads: What the Evidence Says
- Instructional Leadership for DepEd School Heads
- Principal, Head Teacher or Teacher-in-Charge in DepEd
- OPCRF for DepEd School Heads in 2026: What Applies Now
- RA 9155 at 25: Why Shared Governance Has Not Happened
- On the app: The roles of a school head, the six roles in one guide, and the PPSSH guide
Sources
- Republic Act No. 6713, Code of Conduct and Ethical Standards for Public Officials and Employees (1989), Sections 2 to 12, Lawphil Project.
- Rules Implementing the Code of Conduct and Ethical Standards for Public Officials and Employees, Civil Service Commission, April 21, 1989, Rule X.
- Republic Act No. 3019, Anti-Graft and Corrupt Practices Act, Sections 3 and 14, Official Gazette.
- Republic Act No. 10951 (2017), Section 40, amending Article 217 of the Revised Penal Code on malversation, Lawphil Project.
- Presidential Decree No. 1445, Government Auditing Code of the Philippines, Sections 2, 4, 73, 101 to 106, 123 and 124, Lawphil Project.
- Executive Order No. 292, Administrative Code of 1987, Book V, Title I, Subtitle B, Chapter 7, Section 42, Lawphil Project.
- Republic Act No. 9155, Governance of Basic Education Act of 2001, Section 7, Official Gazette.
- Republic Act No. 4670, Magna Carta for Public School Teachers, Sections 7 to 9, Lawphil Project.
- Republic Act No. 7836, Philippine Teachers Professionalization Act of 1994, Sections 9 and 23, Lawphil Project.
- Republic Act No. 12009, New Government Procurement Act (2024), Sections 39, 81 and 92, Lawphil Project.
- DepEd Order No. 024, s. 2020, National Adoption and Implementation of the Philippine Professional Standards for School Heads.
- DepEd Order No. 006, s. 2026, Guidelines on Ensuring a Safe and Motivating Learning Environment, Standardized Code of Conduct.
- DepEd Order No. 049, s. 2022, Amendments to DepEd Order No. 047, s. 2022 (Promotion of Professionalism in the Implementation and Delivery of Basic Education Programs and Services).
- DepEd Order No. 008, s. 2019, Revised Implementing Guidelines on the Direct Release, Use, Monitoring and Reporting of MOOE Allocation of Schools, Section VI.
- DepEd Memorandum No. 041, s. 2024, Reiteration of the “No Collection Policy” in Schools.
- DepEd Memorandum No. 069, s. 2025, Administration of the National Assessment for School Heads for Fiscal Year 2025.
- National Guidelines on Internal Control Systems, Department of Budget and Management, issued through Circular Letter No. 2008-8, October 23, 2008.
- COA-DBM Joint Circular No. 2024-1, Revised Manual on the Disposal of Government Properties, January 30, 2024.
- Committee of Sponsoring Organizations of the Treadway Commission (COSO), Internal Control–Integrated Framework, 1992, updated 2013.
- Markkula Center for Applied Ethics, Santa Clara University, “A Framework for Ethical Decision Making”, revised November 5, 2021.
- Rushworth M. Kidder, How Good People Make Tough Choices, 1995.
Written by Mark Anthony Llego for NASH Reviewer. Sources: Republic Act Nos. 6713, 3019, 9155, 4670, 7836, 10951 and 12009; the CSC Rules Implementing RA 6713; Presidential Decree No. 1445; the Administrative Code of 1987; DepEd Orders No. 024, s. 2020, No. 008, s. 2019, No. 049, s. 2022 and No. 006, s. 2026; DepEd Memoranda No. 041, s. 2024 and No. 069, s. 2025; DBM National Guidelines on Internal Control Systems; COA-DBM Joint Circular No. 2024-1; COSO; Markkula Center for Applied Ethics; Kidder (1995).