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Del Rosario vs. People

MELITA O. DEL ROSARIO, PETITIONER, V. PEOPLE OF THE PHILIPPINES, RESPONDENT

G.R. No. 199930 | 2018-06-27

D E C I S I O N
 
BERSAMIN, J.:
 
To be resolved is whether or not the eight-year prescriptive period for the offense the petitioner committed in violation of Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees) should be reckoned from the filing of the detailed sworn statement of assets, liabilities and net worth (SALN), or from the discovery of the non-filing thereof.
 
It is notable that the informations filed against the petitioner alleged her violation of R.A. No. 6713 for having "fail[ed] to file her detailed sworn SALN for the year 199011991, which the law requires to be...