administrative responsibility would generate a penalty fine and that the Comptroller may impose sanctions of suspension, dismissal, or disqualification from holding public office:34 Article 105: Upon a declaration of administrative responsibility, pursuant to that enshrined in Articles 91 and 92 of this Law, one will be punished with a fine as set in Article 94, in accordance with the severity of the offense and the type of detriment caused. It so corresponds to the Comptroller General of the Republic, in an exclusive and excluding manner, without other proceedings, to call upon the attention of the entity that committed the illicit act, the suspension of the exercise of said charge without salary benefits for a period of no more than twenty-four (24) months or the dismissal of the person deemed responsible, a punishment whose execution will be the responsibility of those of the highest authority; and to impose, heeding to the severity of the irregularity committed, the disqualification from holding public office for a maximum of fifteen (15) years, case in which the relevant information must be submitted to the agency responsible for administration of human resources of the entity or body where the events took place in order for it to carry out the relevant procedures. In those cases where administrative responsibility is declared of the highest authority, the sanction will be executed by the body charged with appointment, removal, or disqualification. The maximum authorities of the bodies and entities established in the numerals 1 to 11 of Article 9 of this Law, before proceeding with the appointment of any public official, are obligated to consult the registry of those disqualified created and maintained by the Comptroller General of the Republic. Any appointment done outside of this rule will be deemed null. 34. On July 9, 2007, the Comptroller General issued an official letter addressed to the Mayors of the country regarding the application of sanctions established in Article 105 of the LOCGRSNCF.35 Pursuant to the official letter, the imposition of the sanctions of suspension, dismissal, or disqualification “require, as the only and exclusive assumption for a declaration of administrative responsibility, that it be the result of a prior, preparatory, and necessary proceeding to allow the application, considering the type and severity of the crime, of the mentioned sanctions.” The Comptroller specified that “the sanctions mentioned, apart from the pecuniary nature alluded to in Article 105 eiusdem, are acts established as a consequence, once the administrative illicit act is proven and the administrative responsibility is determined.” In this context, it noted that: a) “the sanction of suspension from the exercise of a public charge without paid leave, implies for the recipient, the temporary separation, in the conditions alluded to, from the charge held at the moment of the execution. Once the action is verified, the official may be reincorporated into the exercise of public office to the same conditions that existed prior to the sanction becoming effective. b) "[r]egardling the dismissal of the person responsible, [...] it involves breaking the link or relationship between the recipient and [the] entity or agency which he or she provides services for at the moment when the measure is applied." c) "[f]or its part, the disqualification from holding public office for up to fifteen (15) years, results in, as in the case referred to [...] previous[ly], on the one hand, the rupture or dissolution of the employment relationship that may exist for the period the disqualification is sought, and [on] the other hand, the total inability to hold any other public office for the duration of the disqualification." 35. The Comptroller indicated that the noncompliance of the instructions it imparts regarding the execution of these sanctions generates responsibilities for the respective omissions of such responsibility; impose fines in cases referred to in Article 94 of this Law; impose the sanctions referred to in Article 105 of this Law. Cf. Article 93 of the Organic Law of the Comptroller General of the Republic and the National System of Fiscal Oversight, supra note 29, folio 79. 34 Organic Chapter IV of the LOCGRSNCF, entitled: of the Administrative Proceeding for the Determination of Responsibility. Cf. Law of the Comptroller General of the Republic and the National Fiscal Oversight System, supra note 29, folios 79 and 80. 35 Cf. Official letter No. 01-00-00104 of July 9, 2007 issued by the Comptroller General of the Republic and the Mayors of the Bolivarian Republic of Venezuela (case file of annexes to the application, annex 34, folios 1555 to 1558). 17