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Joint Position Paper (For Respondents) : Regional Internal Affairs Service 11

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Republic of the Philippines

NATIONAL POLICE COMMISSION


PHILIPPINE NATIONAL POLICE
REGIONAL INTERNAL AFFAIRS SERVICE 11
xxxxxxxxx

IN RE: ADMINISTRATIVE PROCEEDINGS ADMIN CASE NO.


RIAS11-_____________
AGAINST

PO2 ______________
PO1 _____________
PO2 ______________
PO1_______________

FOR: GRAVE DISHONESTY

Respondents
x--------------------x

JOINT POSITION PAPER


( For Respondents)
Comes now, respondents unto this Honorable Office, most respectfully
submit this Position Paper by averring that:

Preliminary Statement
“Good faith is ordinarily used to describe that state of mind
denoting honesty of intention, and freedom from knowledge of circumstances
which ought to put the holder upon inquiry; an honest intention to abstain from
taking any unconscientiously advantage of another, even through technicalities of
law, together with absence of all information, notice, or benefit or belief of facts
which render transaction unconscientiously.’’

‘’One cannot be dishonest and one cannot commit the offense of Grave
Dishonesty if he does not have the intention to be dishonest and to commit the
same.”

Nature of the Case


This is a case of Grave Dishonesty arising from a violation of Rule 6, Sec.
1, Para C of NMC No. 2016-002 on the ground that both respondents ( PO2___)
allegedly helping one another in switching the urine sample of PO1 _________ to
the urine sample of PO1 __________ during a random drug test conducted by
PNP SOCO.

Statement of Facts
The crux of the foregoing case can be traced back on an incident of a
random drug test on May 25, 2018 at around 9:00 AM wherein which paragraph
8 of the Facts of the Case of the Muto Proprio Investigation Report of ________
PIAS clearly stated;

Issues
WHETHER OR NOT PO2 __________ GUILTY OF GRAVE
DISHONSETY ARISING FROM VIOLATION OF RULE 6, SECTION 1,
PARAGRAPH C OF NAPOLCOM MEMORANDUM CIRCULAR NO. 2016- 002.

Arguments and Discussion

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