9. Termination of Official Relation

Four possibilities for permanent vacancy during term of office

• Death;
• Removal (by impeachment);
• Resignation;
• Permanent Disability

The Guarantee of Security of Tenure for Primarily Confidential Positions

Security of tenure protects these officials. Loss of confidence may nevertheless end their official relation when it results in the expiration of their term of office, rather than their removal.

The CSC cannot take an employee’s computer backup files to determine whether the employee acted as counsel for persons with cases before the Commission if the employee had a reasonable expectation of privacy and the intrusion was unreasonable. In assessing that expectation, consider:

• The employee’s relationship to the files;
• Whether the employee took steps to keep the files private; and
• Whether the files were within the employee’s immediate control.

Pollo v. Constantino-David, G.R. No. 181881, October 18, 2011.