Bautista v. Guevarra
REITERATIONFacts
The Antecedents: Complainant Sergio V. Bautista filed a disbarment complaint against Municipal Judge Loreto Guevarra, alleging that Guevarra received P600.00 from Bautista to facilitate the dismissal of a criminal complaint for Violation of Article 195 of the Revised Penal Code (Jueteng) filed against Bautista and his nephew. Bautista also claimed Guevarra had previously received P500.00 for the same purpose. Guevarra was arrested by NBI agents on October 4, 1978, while receiving the marked P600.00. Procedural History: The Supreme Court referred the case to Executive Judge Flordelis P. Navarro for investigation. Guevarra moved to dismiss, arguing the complaint was politically inspired and that the matter was sub judice as it was pending appeal before the Supreme Court in G.R. No. L-56692. Executive Judge Navarro dismissed the administrative case as moot and academic due to the implementation of Batas Pambansa Blg. 129. The Supreme Court found this order untenable. The Petition: The Supreme Court reviewed the administrative case following the dismissal order by the Executive Judge and took judicial notice of the conviction of respondent Judge Guevarra by the Sandiganbayan in Criminal Case No. 687 for violation of the Anti-Graft and Corrupt Practices Act, which was affirmed by the Supreme Court in G.R. No. L-56692.
Issue(s)
Whether the administrative case against respondent Judge Guevarra should be considered moot and academic due to the implementation of Batas Pambansa Blg. 129. Whether the conviction of respondent Judge Guevarra for violation of the Anti-Graft and Corrupt Practices Act is sufficient ground for disbarment.
Ruling
The Supreme Court resolved to consider the judgment of conviction against respondent Loreto Guevarra as sufficient ground for his disbarment and ordered his name stricken from the Rollo of Attorneys.
Ratio Decidendi
On whether the administrative case should be considered moot and academic: The Supreme Court held that the order of Executive Judge Navarro dismissing the administrative case as moot and academic was untenable. While the implementation of Batas Pambansa Blg. 129 led to a judicial revamp, the Supreme Court's own resolution dated February 15, 1983, provided an exception for cases with compelling reasons to the contrary. Furthermore, the Court emphasized that it alone should decide the appropriate action in such cases, not the investigating executive judge. The dismissal would be all the more improper given the respondent's conviction. On whether the conviction is sufficient ground for disbarment: The Supreme Court found that respondent Judge Guevarra was convicted by the Sandiganbayan in Criminal Case No. 687 for violation of the Anti-Graft and Corrupt Practices Act. This conviction was affirmed by the Supreme Court in G.R. No. L-56692, where the petition for review was dismissed for lack of merit, finding that the factual findings of the lower court were supported by substantial evidence. The Sandiganbayan sentenced Guevarra to an indeterminate prison term and perpetual disqualification from public office. The Court concluded that this conviction constitutes sufficient ground for disbarment.
Main Doctrine
A conviction for violation of the Anti-Graft and Corrupt Practices Act is sufficient ground for disbarment, notwithstanding the implementation of judicial reforms that might otherwise render an administrative case moot and academic.