How the CSC's New SALN Rules could potentially restore accountability in public service

By: Atty. Martin Patricio Senador and Antonio Sebastian O. Rosales | 28 November 2025

It’s a rumor that always sparks public curiosity: "Did you hear? So-and-so official is now using private helicopters and air assets?" Whether grounded in fact or pure tsismis, such talk strikes at the heart of public curiosity: how exactly did they accumulate such wealth far beyond their government salary?

In the Philippines, the official mechanism designed to answer that question is the Statement of Assets, Liabilities, and Net Worth, or SALN. This document is the ultimate "lifestyle check" on paper, a tool forged during the 1986 People Power Revolution, which toppled a dictatorship built on plunder. Yet, in a bitter twist of irony, the very tool designed to bring transparency to Philippine governance was, for five long years, locked away. Now, in the final months of 2025, a sudden reversal in policy has thrust it back into the light, forcing us to ask: Is the SALN truly a tool for the people, or just a political weapon awaiting its next target?

Why the SALN Exists?

First, let's establish what this document is and why it exists. The SALN is not a bureaucratic suggestion; it is a constitutional mandate. Born from the anti-kleptocracy spirit of the 1987 Constitution, it is enshrined in Article XI, Section 17, which states:

A public officer or employee shall, upon assumption of office and as often thereafter as may be required by law, submit a declaration under oath of his assets, liabilities, and net worth.[1]

This constitutional command is implemented by Republic Act No. 6713, the Code of Conduct and Ethical Standards for Public Officials and Employees.[2] The SALN's purpose is twofold: first, to establish a baseline of an official's wealth upon entering office, and second, to monitor that wealth annually. Any sudden, inexplicable surge in "Net Worth" that far outpaces an official's salary is a glaring red flag for "unexplained wealth" and potential corruption.

The new 2025 Omnibus Rules on the SALN, issued by the Civil Service Commission (CSC),[3] aim to modernize the process and clarify long-standing ambiguities that have led to both administrative confusion and, at times, political misuse.

For instance, the new rules finally provide clear answers to old, confusing questions. What about a spouse who is a private citizen? The rules are now explicit: their exclusive "paraphernal or capital property" is not to be declared or included in the net worth computation (Rule III, Sec. 53). What about the fear of "weaponization" over minor details? The rules now protect filers by stating that "specific details are not required, such as the... plate number, motor engine number, and bank account number" (Rule III, Sec. 15).

The rules are meticulous on valuation, too. How do you declare an inherited property? The rules state you must declare its fair market value and assessed value, but its "acquisition cost" is listed as "N/A" since it was received gratuitously (Rule III, Sec. 44). Still paying for a certain real property? You only declare "the amount already paid" as an investment, not the full future value (Rule III, Sec. 38). 

Finally, the rules bring the bureaucracy into the 21st century, providing a detailed step-by-step procedure for digital filing and online oath-taking via recorded video calls (Rule VIII). The 2025 framework also balances transparency with privacy, allowing for the redaction of sensitive personal information like the names of minor children, home addresses, and signatures before a SALN is released to the public (Rule X, Sec. 114).³

This document is the resibo. It is the public's primary evidence to hold officials to the standard of "simple living" that R.A. 6713 demands. Yet, as history shows, a receipt serves no purpose if the people are not allowed to read it.

The SALN as a Sword: A History of Accountability

For a time, the SALN proved it had teeth. It was not just a piece of paper; it was a sword of accountability. Its power was most devastatingly demonstrated in 2012.

The impeachment trial of Chief Justice Renato Corona became a national civics lesson. The Senate, sitting as an impeachment court, voted to convict him for his failure to truthfully declare his assets.[4] The trial revealed that millions of pesos in his bank accounts were conspicuously absent in his SALN. This landmark case demonstrated the SALN’s potential as a sword of accountability, a document that could unseat event the highest magistrate.

Yet, the very same instrument would later be used as a weapon for political reprisal. In 2018, Chief Justice Maria Lourdes Sereno, a vocal critic of the administration at the time, was not impeached. Instead, she was removed from office through a quo warranto petition, after the Supreme Court ruled that she had failed to file several SALN during her time as a professor at the University of the Philippines, years before her appointment. ⁵ While the decision emphasized the constitutional requirement of "proven integrity," it also raised fears that the SALN had become a convenient legal tool for political elimination.

The Sereno ouster poisoned the well. It created a powerful narrative that the SALN was no longer just a tool for fighting corruption, but a political weapon to be used against one's enemies. How, then, do we balance the public’s right to know against an individual's right to be shielded from a purely political vendetta?

The Martires Memo and the Era of Secrecy

This "weaponization" narrative provided the perfect justification for what came next. In 2020, former Ombudsman Samuel Martires, citing the need to protect officials from malicious reportage and fishing expedition issued Memorandum Circular No. 1, Series of 2020.[5]

This circular effectively closed the door the on public and media access to the wealth declarations of high-ranking officials, including the President, Vice President, and members of Congress. Under the circular, SALN of top officials would only be released under three near-impossible conditions, that is, if the requester has either of the following:

1.     The explicit, written consent of the declarant (the official) himself,

2.     A direct order from a court in relation to a pending case, or

3.     A request from the Ombudsman's own field investigation office.[6]

For five years, from 2020 to 2025, the era of SALN-based investigative journalism ground to a halt. Journalists and watchdog groups who had used the annual release of SALNs to track the ballooning wealth of officials were left with nothing. Was an official's net worth suddenly doubling every year? We simply had no way of knowing. This move was widely condemned as a massive step backward for transparency, transforming the resibo ng bayan into a private secret.

This secrecy became untenable as two major scandals shook public confidence. First was the 2024 Confidential and Intelligence Funds (CIF) scandal which raised questions about the unliquidated millions under the Office of the Vice President and the Department of Education.[7] Second was the Flood Control Scandal which exposed alleged kickbacks in infrastructure projects, implicating lawmakers and senior officials, including former House Appropriations Chair Rep. Zaldy Co, Sen. Joel Villanueva, and even COA Commissioner Mario Lipana.[8] When the Martires memo was used to block access to the SALNs of these specific officials, public anger shifted from just the corruption to the state-sectioned secrecy protecting it.

A New Dawn: Reversing the Gag on Transparency

Responding to growing public pressure, newly appointed Ombudsman Jesus Crispin Remulla issued a new circular that completely rescinded the 2020 Martires memo.[9]

This seismic shift, which took effect in October 2025, allowed ordinary citizens, journalists, and researchers to request and access the SALN of officials without requiring their personal consent.

This new Ombudsman circular on access finally harmonizes with the CSC's 2025 Omnibus Rules on filing. However, the reform’s impact remains uncertain. While Malacañang publicly welcomed the new policy, it clarified that the President’s own SALN would be released only to “proper authorities,” not the general public.[10] The return to transparency is thus partial and conditional, leaving open the question of whether the highest offices of government will truly lead by example.

The Public's Turn to Watch

The SALN, by itself, is inert. It is not a magic bullet against corruption. It is not just a piece of paper. Its true power is determined by who gets to use it. For five years, it was a restricted-access weapon for political insiders. Today, it has been returned to the public, aligning with the spirit of the CSC's 2025 rules.

The restoration of public access to the SALN is a victory for transparency, but it is not the end of the story. It is a new beginning, and it places the burden of responsibility squarely back on the shoulders of the citizens, the media, and civil society. The resibo ng bayan is no longer a secret. The only question that remains is: will we bother to look?

[1]  1987 Philippine Constitution, Art. XI, Sec. 17.

[2] Republic Act No. 6713, "An Act Establishing a Code of Conduct and Ethical Standards for Public Officials and Employees," (1989).

[3] Civil Service Commission, "Omnibus Rules on the Statement of Assets, Liabilities, and Net Worth (SALN)," (2025).

[4] Lessons of Corona SALNs, Philippine Daily Inquirer, February 11, 2012, available at https://opinion.inquirer.net/22871/lessons-of-corona-salns (last accessed November 7, 2025).

[5] Lifestyle checks used for extortion – Ombudsman, Philippine Daily Inquirer, September 27, 2020, available at https://newsinfo.inquirer.net/1340657/ombudsman-lifestyle-checks-used-for-extortion (last accessed November 7, 2025); Ombudsman Memorandum Circular No. 1, Series of 2020, September 1, 2025.

[6] Ombudsman Memorandum Circular No. 1, Series of 2020, Section 1, September 1, 2025

[7] "House panel flags discrepancies in receipts from Sara-led DepEd, OVP," Philippine News Agency, November 20, 2024, available at https://www.pna.gov.ph/articles/1238336 (last accessed November 7, 2025.

[8] "ICI recommends criminal, admin raps vs Villanueva, Estrada, Co, other execs over flood control scandal," ABS-CBN News, October 29, 2025, available at https://www.abs-cbn.com/news/nation/2025/10/29/-ici-recommends-raps-vs-jinggoy-villanueva-co-other-execs-over-flood-control-scandal-1206 (last accessed on November 7, 2025).

[9] " Remulla reopens SALNs to public," The Philippine Star, October 15, 2025, available at https://www.philstar.com/headlines/2025/10/15/2480019/remulla-reopens-salns-public (last accessed on November 7, 2025)

[10] "Palace: Marcos, Cabinet execs to release SALN to ‘proper authorities’," Philippine Daily Inquirer, October 26, 2025 available at https://newsinfo.inquirer.net/2130193/palace-marcos-cabinet-execs-to-release-saln-to-proper-authorities (last accessed on November 7, 2025). Disclaimer: The views and opinions expressed in this article are those of the authors and do not necessarily reflect the views and opinions of the Firm or any of its partners. This article shall not be construed as official legal advice from the Firm. 

Atty. Martin Patricio M. Senador is a lawyer who obtained his Bachelor of Sports Science from University of the Philippines, Diliman in 2015 and Juris Doctor from the De La Salle University, College of Law in 2020. He has considerable experience in dispute resolution.

Antonio Sebastian O. Rosales is a paralegal who earned his Bachelor of Science degree in Legal Management from De La Salle University. He is currently completing his Juris Doctor Degree at the University of Santo Tomas.

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