Whistleblowing and integrity in the GOCC sector
By: Atty. Euney Marie J. Mata-Perez on September 3, 2026
WHISTLEBLOWING, or reporting a wrongdoing or misconduct, does not just make government officials accountable; it is the cornerstone to the protection of integrity. Without doubt, it is something that should be strongly promoted and encouraged.
A public office is a public trust, and any abuse of that trust, especially if it amounts to a wrongdoing, must be reported and be subject to appropriate action. Thus, it is important to create an environment that highly encourages the public and government employees to report any wrongdoing or misconduct in government. This can only happen if whistleblowers are guaranteed specific protections.
Toward this end and pursuant to the powers vested upon it, the Governance Commission for GOCCs (government-owned and controlled corporations), or the GCG, issued Memorandum Circular 2025-01, dated Jan. 13, 2025, establishing the Whistleblowing and Integrity Program (WHIP), and providing a framework for reporting acts or omissions that may violate or erode integrity in the GOCC sector. The circular, however, does not just apply to GOCCs; it also applies to government financial institutions and government instrumentalities with corporate powers, including their subsidiaries.
The offenses which may be reported under WHIP are varied. They may include abuse of authority, misconduct, inefficiency, neglect of duty and sexual harassment, as well as violations of laws like the Republic Act (RA) 6713, or the Code of Conduct and Ethical Standards for Public Officials and Employees, RA 3019, or the Anti-Graft and Corrupt Practices Act, and RA 11032, or the Ease of Doing Business and Efficient Government Service Delivery Act.
A central and very important feature of the WHIP is the protection afforded to whistleblowers and the provision of necessary assistance, as warranted by the circumstances of each case. Thus, it allows for whistleblowing to be done anonymously. Reports submitted through the GCG Whistleblowing Portal and designated confidential channels are handled with utmost confidentiality and sensitivity.
The circular also expressly prohibits retaliation against whistleblowers who report in good faith. Prohibited acts include discrimination, harassment and other acts or threats that adversely affect the whistleblower’s rights or interests. These safeguards ensure that whistleblowers are not forced to choose between reporting wrongdoing and protecting their livelihood or rights.
Reporting or whistleblowing can be done in several ways. A report may be made through the whistleblowing portals, which GOCCs are required to prominently display on their websites. It may also be submitted through the dedicated email address provided under the circular. A whistleblower may likewise submit written or recorded communications personally to the appropriate GCG officials. Concerns may also be raised through face-to-face or online meetings with authorized personnel.
After receiving a complaint, the GCG determines the appropriate action based on its contents and circumstances. Vague, unintelligible, repetitive or patently malicious reports may be disregarded while complaints lacking palpable merit or involving forum shopping may be dismissed. For complaints that warrant further action, the GCG may require clarifications, sworn statements and supporting documents; obtain information from relevant persons or entities; conduct interviews, site visits and other fact-finding activities; or refer the matter to the concerned GOCC for appropriate action. It may also seek assistance from government agencies such as the Ombudsman and the National Bureau of Investigation.
Where warranted, the GCG may recommend disciplinary action, institute or recommend proceedings before the appropriate government agency or court, notify the appropriate GCG division regarding a respondent’s disqualification from appointment or reappointment, or direct a special audit. Any disciplinary action remains subject to applicable due process requirements.
Significantly, the circular does not prescribe penalties for reported violations. Instead, it provides a framework for pursuing appropriate administrative, civil or criminal consequences under existing laws and regulations. Sanctions may include suspension, removal, disciplinary proceedings, disqualification from appointment or reappointment or referral to the appropriate authority.
However, the protection under the WHIP does not extend to fabricated or malicious accusations. The GCG is empowered to take legal action against anyone who makes a false or malicious report.
The circular also makes compliance an institutional responsibility. Covered GOCCs must designate a compliance officer, register with the 8888 Citizens’ Complaint Center, establish the required committees and designate appropriate focal persons for alternative dispute resolution.
The submission of a report through any of the modes identified under the WHIP does not prevent a whistleblower from reporting the same concern through other government channels such as the Citizens’ Complaint Center of the Office of the President, the Contact Center ng Bayan of the Civil Service Commission or the eComplaint system of the Bureau of Internal Revenue. These mechanisms complement the WHIP and form part of the broader government effort to address misconduct, improve the delivery of public services, and promote greater efficiency, transparency and accountability.
Ultimately, the WHIP provides a clear avenue for reporting wrongdoing, affords protection to those who report in good faith, allows investigations of credible allegations and ensures that appropriate action is taken against those found responsible. It certainly promotes and strengthens not just accountability, but also integrity in the government sector.
Euney Marie J. Mata-Perez is a CPA-Lawyer and the Managing Partner of Mata-Perez, Tamayo & Francisco (MTF Counsel). She is a corporate, M&A and tax lawyer and has been ranked as one of the top 100 lawyers of the Philippines by Asia Business Law Journal and is the Vice Chair of the Tax Committee of the Management Association of the Philippines. This article is for general information only and is not a substitute for professional advice where the facts and circumstances warrant. If you have any question or comment regarding this article, you may email the author at info@mtfcounsel.com or visit MTF website at www.mtfcounsel.com.
The article was published at the More to Follow Column at The Manila Times on September 3, 2026. Please see this link.