People v. Pactolin
REITERATIONFacts
The Antecedents: The underlying dispute originated from a complaint filed by respondent Atty. Rodolfo D. Pactolin against Mario R. Ferraren, then Officer-in-Charge of Ozamis City. Atty. Pactolin accused Ferraren of illegal disbursement of ₱10,000.00 in public funds, alleging that Ferraren had approved the disbursement based on a falsified letter. This letter, purportedly from Elmer Abastillas, the playing coach of the Ozamis City volleyball team, was presented by Atty. Pactolin as evidence of Ferraren's alleged wrongdoing. Procedural History: Aggrieved by the accusation, Ferraren filed a criminal complaint against Atty. Pactolin for falsification of public document before the Sandiganbayan. The Sandiganbayan found Atty. Pactolin guilty of falsification under Article 172 of the Revised Penal Code and imposed a sentence of imprisonment and a fine. Atty. Pactolin appealed his conviction to the Supreme Court, which affirmed the Sandiganbayan's decision. The Supreme Court, treating the matter as an administrative complaint under Rule 139-B of the Rules of Court, referred the case to the Integrated Bar of the Philippines (IBP) for appropriate action. However, the IBP dismissed the administrative case due to the complainant's failure to appear. The Petition: This case before the Supreme Court, arising from the administrative referral, concerns the disbarment of Atty. Rodolfo D. Pactolin. The Court is tasked with determining whether his conviction for the crime of falsification, a crime involving moral turpitude, warrants his disbarment from the practice of law. Atty. Pactolin argued that the Court's previous decision affirming his conviction was factually infirm. The Supreme Court, however, reiterated that a final and executory conviction for a crime involving moral turpitude is a sufficient ground for disbarment under Section 27, Rule 138 of the Rules of Court, and that it is no longer required to review the judgment of conviction.
Issue(s)
Whether Atty. Pactolin should be disbarred after conviction by final judgment of the crime of falsification. Whether the crime of falsification of public document involves moral turpitude.
Ruling
The Supreme Court disbarred Atty. Rodolfo D. Pactolin and ordered his name removed from the Rolls of Attorneys. The Court held that his conviction for falsification of public document, a crime involving moral turpitude, warrants disbarment.
Ratio Decidendi
On whether Atty. Pactolin should be disbarred after conviction by final judgment of the crime of falsification: The Court reiterated that in disbarment cases, it is no longer called upon to review a judgment of conviction that has become final and executory. The conviction of Atty. Pactolin for falsification of public document by the Sandiganbayan, which was affirmed by the Supreme Court, established his culpability. The Court relied on the settled rule that one found in possession of and who used a forged document, without a satisfactory explanation, is the forger and guilty of falsification. The finality of the conviction meant that the review of the conviction no longer rested with the Supreme Court in this administrative proceeding. Section 27, Rule 138 of the Rules of Court provides that conviction of a crime involving moral turpitude is a ground for removal or suspension from the practice of law. The Court found that Atty. Pactolin's disbarment was warranted based on his conviction. On whether the crime of falsification of public document involves moral turpitude: The Court affirmed its ruling that the crime of falsification of public document is contrary to justice, honesty, and good morals, and therefore involves moral turpitude. Moral turpitude encompasses acts that are base, vile, or depraved, contrary to accepted rules of right and duty, or conduct contrary to justice, honesty, modesty, or good morals. The Court cited previous jurisprudence, specifically In Re: Disbarment of Rodolfo Pajo, which held that falsification of public document involves moral turpitude. This classification is crucial as it directly links the criminal conviction to the ethical standards required of lawyers.
Main Doctrine
Conviction of a lawyer by final judgment for the crime of falsification of public document, which involves moral turpitude, is a sufficient ground for disbarment under Section 27, Rule 138 of the Rules of Court.