The human predicament ... was that, no matter what, people sin again: private penance, not public penance, is a remedy for those fresh outbreaks. Even Gratian, down in Bologna, argued for repeatability: charity rules that the ancient tradition of public penance should not be enforced, even though its rules should remain on the books. Why? Although Augustine, in other contexts, argued for unrepeatability, Gratian cited the anti-Donatist Augustine, who defined penance as the way of dealing with postbaptismal sin, yet argued that Donatists thought that rebaptism was the only means to reconciliation.
Peter argued for repeatability by citing what seem to be self-contradictory opinions of the authorities. In the first distinction on penance (distinction 14), for instance, he cited Ambrose, Augustine, and Origen that penance is a once-in-a-lifetime event. He then cites Augustine, Ambrose, and John Chrysostom that penance can be repeated as often as sins arise.
The infallible Council of Trent ruled that it was repeatable, private, to a priest, and it always had been, from the moment Christ instituted the sacrament.
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