Collantes v. Renomeron
REITERATIONFacts
The Antecedents: V & G Better Homes Subdivision, Inc. (V & G) sought the registration of 163 deeds of absolute sale with assignment in favor of the Government Service Insurance System (GSIS) for lots mortgaged by buyers. Respondent Atty. Vicente Renomeron, the Register of Deeds of Tacloban City, failed to act on these requests starting January 1987. Despite V & G complying with tax requirements, Renomeron suspended registration pending a 'special arrangement' where V & G would provide him with weekly round-trip tickets from Tacloban to Manila plus P2,000.00 pocket money, or alternatively, the sale of his house in Quezon City. On May 19, 1987, he accepted P800.00 for a plane ticket but later imposed additional requirements when the pocket money was not provided. Procedural History: Complainant Collantes, house counsel for V & G, filed administrative charges with the National Land Titles and Deeds Registration Administration (NLTDRA). On May 22, 1987, Renomeron formally denied registration, claiming the deeds were ambiguous. The NLTDRA Administrator, in Consulta No. 1579, ruled the documents were registrable, yet Renomeron still refused to act. Following an investigation, the Secretary of Justice found Renomeron guilty of grave misconduct. On May 3, 1990, President Corazon Aquino issued Administrative Order No. 165, dismissing Renomeron from government service with forfeiture of benefits. The Petition: Parallel to the administrative case, Collantes filed this disbarment complaint before the Supreme Court on June 16, 1987. The complaint charged Renomeron with neglect of duty, conduct unbecoming of a public official, dishonesty, extortion, and gross ignorance of the law. Renomeron denied the extortion charges but waived his right to a formal investigation, submitting the case based on the pleadings and the findings of the NLTDRA and the Department of Justice.
Issue(s)
Whether a lawyer may be disciplined by the Supreme Court for malfeasance committed in his capacity as a public official.
Ruling
Respondent Atty. Vicente C. Renomeron is DISBARRED, and his name is ordered stricken off the Roll of Attorneys.
Ratio Decidendi
On the Issue of Disciplinary Action for Public Officials: The Court ruled that a lawyer's misconduct as a public official also constitutes a violation of his oath as a lawyer. Under Canon 6 of the Code of Professional Responsibility (CPR), the ethical rules apply to lawyers in government service in the discharge of their official tasks. The Lawyer's Oath requires every lawyer to 'delay no man for money or malice,' and its violation is a ground for suspension or disbarment. The Court emphasized that membership in the Bar is a mandate to public service of the highest order, requiring qualities of truth-speaking, honor, and intellectual honesty. Rule 1.01 of the CPR forbids a lawyer from engaging in unlawful, dishonest, or deceitful conduct, while Rule 7.03 prohibits behaving in a scandalous manner that discredits the legal profession. In this case, Renomeron's extortionate tactics and refusal to perform his duty despite clear administrative rulings demonstrated a lack of moral character. Consequently, his dismissal from the civil service did not preclude the Court from exercising its power to disbar him for his unfitness to remain in the legal profession.
Main Doctrine
The Supreme Court holds that a lawyer may be disciplined for misconduct committed while in government service. The Code of Professional Responsibility (CPR) specifically applies to lawyers in the discharge of their official tasks under Canon 6. Any act of dishonesty, oppression, or extortion committed by a lawyer-official not only violates civil service rules but also breaches the Lawyer's Oath and the ethical standards of the legal profession, reflecting adversely on their fitness to practice law. The Court's power to disbar is independent of the administrative penalties imposed by the executive branch.