Cbd 251; (July, 1995) (Digest)
CBD Case No. 251 July 11, 1995
Adelina T. Villanueva, complainant, vs. Atty. Teresita Sta. Ana, respondent.
FACTS
Complainant Adelina T. Villanueva sought the disbarment of respondent Atty. Teresita Sta. Ana. In April 1992, complainant entrusted Atty. Sta. Ana with P144,000.00 as a “guaranty deposit” and various property documents to facilitate a loan application. Respondent later demanded an additional P109,000.00 for purported taxes. Complainant then decided to forego the loan and demanded the return of her money, but respondent failed to comply and began avoiding her.
The complaint was referred to the National Bureau of Investigation (NBI), which recommended criminal and disbarment proceedings. The Integrated Bar of the Philippines (IBP) Commission on Bar Discipline required respondent to answer, but she neither filed a response nor appeared at hearings. The Commission also noted multiple pending criminal cases against respondent, including a conviction for Estafa through Falsification of Public Document where she was sentenced to imprisonment and ordered to indemnify the victim.
ISSUE
Whether respondent Atty. Teresita Sta. Ana should be disbarred for conduct unbecoming a member of the Bar.
RULING
Yes, the Supreme Court ordered the disbarment of Atty. Teresita Sta. Ana. The legal logic is anchored on the fundamental requirement of good moral character for the continued practice of law, as mandated by the Code of Professional Responsibility. Canon 1, Rule 1.01 prohibits lawyers from engaging in unlawful, dishonest, or deceitful conduct. Canon 16 requires a lawyer to hold client funds in trust and to account for them.
Respondent’s actions—obtaining a substantial sum and documents from complainant under false pretenses, failing to return them upon demand, and evading investigation—constitute gross misconduct and a blatant violation of these ethical canons. Her conviction for a serious crime involving moral turpitude (Estafa through Falsification) is conclusive evidence of her unfitness to remain in the legal profession. Her failure to participate in the disciplinary proceedings or offer any defense further underscores her disregard for legal processes. The Court, adopting the IBP’s findings, held that such conduct renders her totally unfit to be a lawyer, warranting the ultimate penalty of disbarment to protect the public and the integrity of the legal profession.