G.R. No. A.M. No. 1814 April 13, 1978
Carmen M. Orozco, complainant, vs. Atty. Salvador N. Beltran, respondent.

FACTS

Carmen M. Orozco, a retired professor, filed a verified administrative complaint against Atty. Salvador N. Beltran, who was her lessee of an apartment in Quezon City. The complainant alleged that the respondent lawyer committed numerous infractions of their lease contract, conduct which she claimed demonstrated a lack of respect for the law he swore to uphold as a member of the bar.
In his comment, respondent Beltran argued that the complainant’s grievances, pertaining to alleged breaches of a lease agreement, were purely civil in nature and should properly be ventilated in an ejectment suit or other civil case, not in a disciplinary proceeding against him as a lawyer. He also recounted the background of the lease and legal services he had previously rendered to Orozco. Subsequently, the respondent manifested his intention to vacate the apartment, which he did, and the complainant regained possession.

ISSUE

Whether the respondent lawyer may be administratively disciplined based on alleged breaches of a civil lease contract between him and the complainant.

RULING

No. The Supreme Court dismissed the administrative case. The Court clarified that the alleged infractions of the lease contract by the respondent, even if true, pertain to private civil obligations arising from a contractual landlord-tenant relationship. Such grievances do not, by themselves, constitute professional misconduct or warrant disciplinary action under the attorney’s oath. Administrative proceedings against lawyers are designed to address violations of professional duties and ethical standards integral to the legal profession, not to adjudicate ordinary breaches of private contracts.
The complainant’s subsequent prayer for the Court to order the payment of back rentals, a refund for shares of stock, and a legal fee refund underscored the essentially civil character of her claims. The Court explicitly held that such monetary relief cannot be granted in an administrative disciplinary case. The proper remedy for the complainant lies in filing a separate civil action to recover these alleged sums. Since the core dispute was civil and the respondent had already vacated the premises, the Court considered the administrative case terminated. This resolution reinforces the principle that the disciplinary machinery of the Supreme Court is not a substitute for a civil court to enforce private contractual rights.