AM 924; (December, 1981) (Digest)
G.R. No. A.M. No. 924 December 28, 1981
RENATO M. CORONADO, complainant, vs. ATTORNEY ANGEL S. HUERTAS, respondent.
FACTS
The complainant, Renato M. Coronado, filed a disbarment complaint against respondent Attorney Angel S. Huertas, a former Municipal Judge of Ragay, Camarines Sur. The complaint alleged that Huertas falsified an information sheet submitted to the Commission on Appointments for the confirmation of his judicial appointment. Specifically, he was accused of falsely stating that he had no previous administrative case. In truth, the Civil Service Board of Appeals had affirmed a decision finding him guilty of dishonesty and gross misconduct for falsifying daily time records during his prior government service as a Senior Inspector of the Fiber Inspection Service, which resulted in his dismissal.
In his Answer, respondent Huertas denied the allegation. He contended that the confirmation of his dismissal by the Civil Service Board of Appeals occurred after the City Fiscal of Manila had already dismissed a related criminal case for falsification filed against him by the Fiber Inspection Service. Huertas argued that the dismissal of the criminal case extinguished his corresponding liabilities. The case was subsequently referred to the Solicitor General for investigation, report, and recommendation.
ISSUE
Whether the disbarment proceedings against Attorney Angel S. Huertas should proceed given the supervening event of his death.
RULING
The Supreme Court dismissed the complaint for being moot and academic. The legal logic is grounded in the principle that disbarment proceedings are personal and punitive in nature, aimed at protecting the public and the integrity of the legal profession by removing an unfit lawyer. Upon the death of the respondent lawyer, the primary purpose of the proceedings—to discipline the living member of the bar—is rendered inoperative. There no longer exists a person to sanction or to protect the public from.
The Court, following established jurisprudence cited in the Solicitor General’s Report, notably Fule v. Cordero, Lazaro v. Sagun, and Calamba II v. Delgra, Jr., consistently holds that the death of the respondent during the pendency of disbarment cases abates the action. The Court’s disciplinary authority ceases as it cannot impose penalties, such as suspension or disbarment, upon a deceased individual. Consequently, continuing the proceedings would serve no practical legal purpose. Therefore, the case was terminated without a ruling on the substantive merits of the falsification allegations due to this supervening event.