Case Digest: Madreo vs. Bayron, G.R. No. 237330, November 03, 2020

The Supreme Court elucidates the applicability of the Condonation Doctrine, otherwise known as the Aguinaldo Doctrine, following its abandonment in Carpio-Morales vs. Binay in 2016.

On whether or not the doctrine is still applicable in the consolidated cases (GR No. 237330, Madreo v. Bayron; GR No. 237579, Ombudsman v. Bayron, November 3, 2020),the Supreme Court sheds light on the prospective application of the abandonment of condonation doctrine. The Court emphasized that elected public officials, re-elected on or after April 12, 2016, can no longer avail the doctrine as defense for previous misconduct.

Here, the Supreme Court En Banc affirmed the Court of Appeals’ dismissal of the administrative charges for serious dishonesty, grave misconduct and falsification of Public Document against Lucilo R. Bayron, former mayor of Puerto Princesa City, Palawan, and his son Karl Bayron by reason of the former’s re-election during the 2015 recall elections, wherein the abandonment of the condonation doctrine was yet to take effect.