Parcasio v. People
REITERATIONFacts
The Antecedents: Atty. Saturnino Parcasio was convicted of robbery with intimidation by the Court of First Instance of Davao, a decision affirmed by the Court of Appeals and this Court. The robbery involved extorting P200 from Venancio Sepulveda by posing as agents of Congressman Rasid Lucman, to prevent Sepulveda from appearing in Manila for an investigation. Procedural History: The Court, upon reviewing Parcasio's case, referred it to the Solicitor General for disbarment proceedings. A complaint was filed against Parcasio for committing a crime involving moral turpitude. Parcasio sought to reopen his case based on newly discovered evidence, including an affidavit from a patrolman stating Sepulveda admitted Parcasio did not extort money, and a summons for Sepulveda to appear before a congressional subcommittee. The Petition: During the pendency of the disbarment proceedings, Parcasio was granted an absolute and unconditional pardon by the President of the Philippines, restoring him to full civil and political rights. He then filed a manifestation praying for the dismissal of the disbarment case based on this pardon. The Solicitor General and the Integrated Bar of the Philippines offered no objection to the dismissal.
Issue(s)
Whether a disbarment proceeding against a lawyer should be dismissed in view of an absolute and unconditional pardon granted to him during the pendency of the case. Whether a crime involving moral turpitude, for which a lawyer was convicted, can be considered as having been expunged from his record by virtue of a plenary pardon.
Ruling
The Court dismissed the disbarment case against Atty. Saturnino Parcasio.
Ratio Decidendi
On the issue of dismissing the disbarment proceeding due to pardon: The Court held that a plenary pardon granted to Atty. Parcasio during the pendency of the disbarment proceeding warrants its dismissal. This is not an unprecedented issue, as the Court has previously ruled on similar matters. The pardon granted was absolute and unconditional, restoring the offender to all his civil and political rights. The Court cited the principle that a pardon reaches both the punishment and the guilt of the offender. When the pardon is full, it releases the punishment and blots out of existence the guilt, making the offender as innocent in the eyes of the law as if the offense had never been committed. This restoration to civil rights implies a new credit and capacity, effectively making the individual a "new man." On the issue of expunging the crime through pardon: The Court applied the ruling in In re Lontok, which established that a pardon, especially a full pardon, "blots out of existence the guilt, so that in the eye of the law the offender is as innocent as if he had never committed the offense." This means that the conviction for the crime involving moral turpitude, which formed the basis of the disbarment complaint, is effectively nullified in legal contemplation. The pardon removes the penalties and disabilities associated with the conviction, thereby restoring the individual's standing. The Court distinguished this from cases where a conditional pardon was granted, emphasizing that the plenary nature of the pardon in this case is crucial for its effect on the disbarment proceedings.
Main Doctrine
A plenary pardon granted to a lawyer during the pendency of a disbarment proceeding, which restores the offender to all civil rights, warrants the dismissal of the disbarment case, as the pardon blots out guilt and renders the offender as innocent as if the offense had never been committed.