That being said, this Court simply finds no legal authority to sustain
the condonation doctrine in this jurisdiction. As can be seen from this
discourse, it was a doctrine adopted from one class of US rulings way back
in 1959 and thus, out of touch from – and now rendered obsolete by – the
current legal regime. In consequence, it is high time for this Court to
abandon the condonation doctrine that originated from Pascual, and
affirmed in the cases following the same, such as Aguinaldo, Salalima,
Mayor Garcia, and Governor Garcia, Jr. which were all relied upon by the
CA.
It should, however, be clarified that this Court’s abandonment of the
condonation doctrine should be prospective in application for the reason
that judicial decisions applying or interpreting the laws or the Constitution,
until reversed, shall form part of the legal system of the Philippines.305 Unto
this Court devolves the sole authority to interpret what the Constitution
means, and all persons are bound to follow its interpretation. As explained in
De Castro v. Judicial Bar Council:
306
Judicial decisions assume the same authority as a statute itself and,
until authoritatively abandoned, necessarily become, to the extent that they
are applicable, the criteria that must control the actuations, not only of
those called upon to abide by them, but also of those duty-bound to
enforce obedience to them.307
Hence, while the future may ultimately uncover a doctrine’s error, it
should be, as a general rule, recognized as “good law” prior to its
abandonment. Consequently, the people’s reliance thereupon should be
respected. The landmark case on this matter is People v. Jabinal,
308 wherein
it was ruled:
[W]hen a doctrine of this Court is overruled and a different view is
adopted, the new doctrine should be applied prospectively, and should not
apply to parties who had relied on the old doctrine and acted on the faith
thereof.
304 117 N.J.L. 64; 186 A. 818 (1936).
EN BANC CONCHITA CARPIO MORALES, in her capacity as the Ombudsman, Petitioner, - versus - COURT OF APPEALS (SIXTH DIVISION) and JEJOMAR ERWIN S. BINAY, JR., Respondents.
EN BANC CONCHITA CARPIO MORALES, in her capacity as the Ombudsman, Petitioner, - versus - COURT OF APPEALS (SIXTH DIVISION) and JEJOMAR ERWIN S. BINAY, JR., Respondents.
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