G.R. No. L-73751 September 24, 1986
ROMAN R. VILLALON, JR., ET AL., petitioners, vs. HON. INTERMEDIATE APPELLATE COURT, ET AL., respondents.

FACTS

Petitioners, Atty. Roman R. Villalon, Jr. and his sons, were defendants in Civil Case No. 2799 for “Annulment of Deed of Absolute Sale, Recovery of Possession and Damages” filed by private respondents, the Ebuiza family. The case involved a parcel of land in La Union. The same property and deed of sale were the subject of an earlier Disbarment Case (Adm. Case No. 1488) filed against petitioner Villalon, which was pending investigation before the Office of the Solicitor General.
During the trial of the civil case, petitioners sought to introduce the testimonies given by some of the private respondents (Catalina Neval Vda. de Ebuiza, Francisco Ebuiza, and Justina Ebuiza San Juan) in the disbarment proceedings. The purpose was to impeach their credibility in the civil case by showing prior inconsistent statements. Private respondents moved to strike this evidence, arguing it violated the confidentiality of disbarment proceedings under Rule 139 of the Rules of Court.

ISSUE

Whether the trial court committed a grave abuse of discretion in granting the motion to strike the impeaching evidence from the disbarment case on grounds of confidentiality, and whether a petition for certiorari is the proper remedy to challenge such an interlocutory order.

RULING

The Supreme Court granted the petition, setting aside the decisions of the Intermediate Appellate Court and the trial court. The Court held that the trial court’s order striking the evidence constituted a patent abuse of discretion. While the order was interlocutory, certiorari is available to correct such an abuse, especially when an ordinary appeal is inadequate and the broader interests of justice require it.
The legal logic is twofold. First, on procedural grounds, the trial court deprived petitioners of their fundamental right to impeach adverse witnesses using prior inconsistent statements, a right expressly sanctioned under Sections 15 and 16, Rule 132 of the Rules of Court. The suggested remedy of a formal offer of evidence later would be ineffective for impeachment purposes. Second, on substantive grounds, the confidentiality of disbarment proceedings under Section 10, Rule 139 is a privilege intended for the protection of the attorney’s reputation. This privilege can be waived by the attorney concerned. Petitioner Villalon, as the respondent in the disbarment case, validly waived this confidentiality to utilize the testimonies for his defense in the civil case. The Court noted that the subject matter—the validity of the deed of sale—was identical in both cases, making the prior testimonies highly material. Therefore, the trial court erred in disallowing the evidence.