Title
Milanes vs. De Guzman
Case
G.R. No. L-23967
Decision Date
Nov 29, 1968
In Milanes v. De Guzman, the Supreme Court ruled in favor of the petitioner, stating that the administrative charges against the municipal mayor did not constitute misconduct in office as the actions were performed in his private capacity and did not affect his official integrity.
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Case Digest (G.R. No. L-23967)

Facts:

  • The case involves Antonino M. Milanes, the municipal mayor of Agoo, La Union.
  • The charges against Milanes were based on allegations of slander by words, slander by deed, and serious threats.
  • These allegations were supposedly made and committed during a public political rally.
  • The charges were brought against Milanes in his capacity as the municipal mayor.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Milanes, stating that the charges did not cons...(Unlock)

Ratio:

  • The charges did not fall under the category of "conviction by final judgment of any crime involving moral turpitude" because there was no conviction at the time.
  • The grounds of neglect of duty, oppression, corruption, or other forms of maladministration of office only apply to acts or omissions committed or incurred "in office."
  • The acts in question were performed by Milanes while he was acting as a toastmaster in a political rally organized by the Nacionalista Party, not by the government.
  • Therefore, Milanes acted in his private capacity and his actions did not affect his official integrity as the mayor.

Supporting Cases:

  • Lacson v. Roque, Mondano v. Silvosa, and Cornejo v. Naval were cited to support the ruling.
  • These cases established that certain acts committed by mayors, even if related to their office, may not necessarily constitute misconduct in office if they were not performed in the course of their official duties or if they did not make use of the powers of their office.

Additional Ruling:

  • T...continue reading

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