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	GR Nos. 217126-27 2015-11-10	CONCHITA CARPIO MORALES v. CA PERLAS-BERNABE, J.
In Gonzales III v. Office of the President[160] (Gonzales III), the Court traced the historical underpinnings of the Office of the Ombudsman: Prior to the 1973 Constitution, past presidents established several Ombudsman-like agencies to serve as the people's medium for airing grievances and for direct redress against abuses and misconduct in the government. Ultimately, however, these agencies failed to fully realize their objective for lack of the political independence necessary for the effective performance of their function as government critic.
	AM No. SCC-13-18-J 2015-07-01	BAGUAN M. MAMISCAL v. CLERK OF COURT MACALINOG S. ABDULLAH MENDOZA, J.
Almost five (5) months later, however, on February 23, 2011, Adelaidah filed[7] the Certificate of Divorce (COD),[8] dated September 26, 2010, with the office of Abdullah for registration. Although unsigned, the certificate, purportedly executed by Mamiscal, certified that he had pronounced talaq in the presence of two (2) witnesses and in accordance with Islamic Law for the purpose of effecting divorce from Adelaidah. A notation on the certificate stated that it was being filed together with the kapasadan.