Condonation Doctrine G.R. Nos. 217126-27. November 10, 2015

 Conchita Carpio Morales, in her capacity as the Ombudsman, Petitioner, vs. Court of Appeals (Sixth Division) and Jejomar Erwin S. Binay, Jr., Respondents.

[ G.R. Nos. 217126-27. November 10, 2015 ]

Facts:

This case revolves around the issue of whether the condonation doctrine, as applied to elective officials, still holds validity in light of the principles of public accountability and the Ombudsman's disciplinary authority.

Jejomar Erwin S. Binay, Jr. (Binay Jr.) was elected as Mayor of Makati City for multiple terms. During his tenure, the Office of the Ombudsman conducted an investigation into alleged irregularities in the construction of the Makati City Hall Parking Building. The investigation resulted in the filing of administrative and criminal charges against Binay Jr.

However, Binay Jr. argued that he cannot be held administratively liable for the alleged offenses committed during his previous term as Mayor. He relied on the condonation doctrine, which holds that the re-election of a public official condones his previous misconduct or irregularities.

The Ombudsman, represented by Conchita Carpio Morales, filed a petition seeking to nullify the Court of Appeals' decision in favor of Binay Jr. The Ombudsman argued that the condonation doctrine should no longer be applied as it contravenes the constitutional principles of public accountability and the Ombudsman's disciplinary authority.

Issue:

Whether the condonation doctrine remains a valid defense for elected officials in administrative cases.

Ruling:

The Supreme Court ruled in favor of the Ombudsman and declared that the condonation doctrine is no longer a valid defense for elected officials in administrative cases.

The Court emphasized that the condonation doctrine is inconsistent with the constitutional principle of public accountability. Elected officials are entrusted with public office and are expected to be accountable for their actions throughout their term. The re-election of an official should not absolve them of administrative liability for acts committed during a previous term.

Furthermore, the Court recognized the Ombudsman's constitutional mandate to investigate and discipline public officials. It held that the Ombudsman's authority extends to all public officials, regardless of their re-election or term limits. The Ombudsman's disciplinary power is crucial to maintaining integrity and accountability in public service.

In light of these considerations, the Court declared that the condonation doctrine is inconsistent with constitutional principles and jurisprudence. It is no longer a valid defense to shield elected officials from administrative liability for acts committed during a previous term. Therefore, the Court reversed the decision of the Court of Appeals and remanded the case to the Ombudsman for further proceedings.

Conclusion:

The Supreme Court, in this case, held that the condonation doctrine, as applied to elected officials, is no longer a valid defense in administrative cases. The re-election of a public official does not absolve them of administrative liability for acts committed during a previous term. This ruling upholds the principles of public accountability and reinforces the Ombudsman's authority to investigate and discipline public officials.