When Privacy Rights Are Allegedly Violated Inside a Human Rights Office

Former Presidential Staff Officer Giann V. Lim of the Presidential Human Rights Committee Secretariat (PHRCS) has filed complaints against PHRCS Undersecretary Severo S. Catura and Director IV Gerald G. Bitonio over the alleged unauthorized disclosure, circulation, and misuse of a confidential document.

On 29 April 2026, Ms. Lim, through counsel Go & De Guzman Law Offices, filed a complaint before the Office of the President – Internal Affairs and Complaints Committee (IACC) for alleged violation of Section 7(c) of Republic Act No. 6713 and Grave Misconduct under Rule 10, Section 63(A) of the 2025 Rules on Administrative Cases in the Civil Service.

On 17 June 2026, Ms. Lim, with the assistance of GD Law, filed a separate complaint before the National Privacy Commission (NPC) against the same officials for alleged violations of the Data Privacy Act.

Figure 1.

The Confidential BIF

The complaints arose from the alleged misuse of Ms. Lim’s confidential Background Investigation Form (BIF), submitted in connection with her application for the Senior Gender and Development Specialist position with the Philippine Commission on Women (PCW).

Ms. Lim had identified Bitonio, her direct supervisor on matters involving women’s rights and CEDAW compliance, as one of her character references. The PCW then requested Bitonio to accomplish the BIF, which was expressly limited to recruitment and hiring purposes and covered by a Data Privacy Notice prohibiting disclosure to third parties without consent or lawful basis.

However, instead of submitting the BIF by the 16 October 2025 deadline, Bitonio allegedly transmitted the completed BIF to Catura and later copied him in the submission of the same to the PCW on 23 October 2025.

Catura, who allegedly had no role in the PCW application process, later used, attached, and referred to the BIF in his Counter-Affidavit before the Office of the President – Committee on Decorum and Investigation. The CODI proceedings arose from the sexual harassment complaint filed by Ms. Lim against Catura.

The Data Privacy Issue

This case is not merely about an employment application. At its core, it concerns the right to privacy and the protection of personal information.

The Data Privacy Act requires personal data to be processed only for specified, legitimate, and lawful purposes. In Ms. Lim’s case, the BIF was allegedly provided solely for the PCW recruitment process. Its alleged disclosure to Catura and subsequent use in an unrelated adversarial proceeding raise serious questions on unauthorized processing, processing for unauthorized purposes, and unauthorized disclosure.

The complaint before the NPC therefore asks whether the respondents violated the Data Privacy Act when a confidential recruitment document was allegedly used beyond its intended purpose and without Ms. Lim’s knowledge or consent.

Figure 2.

Public Office and Accountability

Apart from privacy violations, Ms. Lim maintains that the acts constitute Grave Misconduct. In Espinas v. Ombudsman, the Supreme Court explained that grave misconduct requires deliberate non-compliance with the law and intent to benefit the offender or another person.

Here, the complaint alleges that the confidential BIF was deliberately used for an unauthorized, unrelated, and prejudicial purpose to benefit Catura.

The irony is difficult to ignore. The respondents are officials of the PHRCS, an institution mandated to protect human rights, including the right to privacy.

As legal counsel for Ms. Giann V. Lim, Go & De Guzman Law Offices remains steadfast in pursuing justice, accountability, and the protection of women’s rights. Public office is a public trust. Lady Justice is a woman — and she must never be used to silence one.