Resurreccion v. Sayson
REITERATIONFacts
The Antecedents: On May 13, 1970, Victoriano P. Resurreccion was involved in a vehicular accident resulting in the death of Armando Basto, Jr. Resurreccion was charged with homicide through reckless imprudence. An amicable settlement was reached where Resurreccion agreed to pay P2,500.00 to the victim's father, Armando Basto, Sr. On August 8, 1970, Resurreccion delivered the P2,500.00 to Atty. Ciriaco C. Sayson, who was the counsel for the offended party. Sayson acknowledged receipt of the money but failed to remit it to his client. As a result, the criminal case was not dismissed, and Resurreccion was forced to pay another P2,500.00 directly to the heirs to settle the matter. Procedural History: Resurreccion filed a complaint for estafa against Sayson in the City Court of Quezon City (Criminal Case No. III-149358) and a simultaneous administrative complaint for disbarment. The City Court found Sayson guilty of estafa, a conviction that was subsequently affirmed by the Court of Appeals and upheld by the Supreme Court. The administrative case was initially investigated by the Office of the Solicitor General (OSG) starting in 1973, but the investigation was delayed for decades. In 1990, the Integrated Bar of the Philippines (IBP) took over the case. The Petition: The IBP Investigating Commissioner, Jesulito A. Manalo, found that the misappropriation was established by convincing evidence, including written acknowledgments of receipt that Sayson never controverted. The IBP Board of Governors adopted the recommendation for disbarment. The case was elevated to the Supreme Court for final action, with the complainant emphasizing Sayson's deceitful conduct and the respondent's failure to participate in the proceedings or return the misappropriated funds despite numerous demands.
Issue(s)
Whether Atty. Ciriaco C. Sayson's conviction for estafa and his misappropriation of funds intended for his client warrant the penalty of disbarment.
Ruling
WHEREFORE, Respondent Ciriaco C. Sayson is hereby DISBARRED. The Clerk of Court is directed to strike out his name from the Roll of Attorneys. SO ORDERED.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that disbarment is the appropriate penalty because the respondent was convicted of estafa, which is a crime involving moral turpitude. Applying the ruling in In re Vinzon, the Court defined moral turpitude as encompassing everything done contrary to justice, honesty, or good morals. Since estafa involves inherent deceit and the unlawful withholding of money, it is unquestionably an act against the moral standards required of a lawyer. The Court further noted that under Villanueva v. Sta. Ana, good moral character is a continuing requirement for Bar membership and must remain extant to maintain good standing. The respondent's conduct—specifically his failure to return the money, his lack of remorse, and his evasion of the disciplinary proceedings—demonstrated a total unfitness to practice law. Furthermore, the Court held that the 27-year delay in the case resolution did not excuse the respondent, as it was largely caused by his own failure to appear and his failure to inform the Integrated Bar of the Philippines (IBP) of his change of address.
Main Doctrine
The Supreme Court emphasizes that lawyers are sacredly bound to uphold the law and live by it. Consequently, any lawyer who violates their oath and engages in deceitful conduct, such as misappropriating funds, has no place in the legal profession. Estafa is explicitly categorized as a crime involving moral turpitude because it is contrary to justice, honesty, and good morals. The power to disbar, while exercised with caution, is necessary when a lawyer's conduct seriously affects their standing and character as an officer of the Court.