Title
Ali vs. Bubong
Case
A.C. No. 4018
Decision Date
Mar 8, 2005
Atty. Bubong disbarred for grave misconduct as Register of Deeds, including imprudent TCT issuance and case manipulation, despite complainant's death and withdrawal request.
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Case Digest (A.C. No. 4018)

Facts:

  1. Background of the Case
    This is a disbarment case filed by Omar P. Ali against Atty. Mosib A. Bubong, who was found guilty of grave misconduct while serving as the Register of Deeds of Marawi City. The disbarment proceeding stemmed from an earlier administrative case filed by the complainant, which involved allegations of illegal exaction, imprudent issuance of a Transfer Certificate of Title (TCT No. T-2821), and manipulation of a criminal complaint for violation of the Anti-Squatting Law.

  2. Administrative Case Findings
    The Land Registration Authority (LRA) initially investigated the case and absolved Atty. Bubong of all charges. However, upon review by the Department of Justice (DOJ), then Secretary Franklin Drilon found Atty. Bubong guilty of grave misconduct for imprudently issuing TCT No. T-2821 and manipulating the criminal case. Secretary Drilon recommended his dismissal from service, which was upheld by former President Fidel V. Ramos through Administrative Order No. 41.

  3. Judicial Proceedings
    Atty. Bubong challenged his dismissal before the Supreme Court, but his petition was dismissed for lack of merit. The Court found no grave abuse of discretion in the issuance of Administrative Order No. 41.

  4. Disbarment Proceedings
    Based on the outcome of the administrative case, Omar P. Ali filed a disbarment complaint against Atty. Bubong, alleging that his actions demonstrated unfitness to remain a member of the legal profession. The Integrated Bar of the Philippines (IBP) investigated the case and recommended a five-year suspension, which the IBP Board of Governors modified to a two-year suspension.

  5. Respondent’s Defense
    Atty. Bubong argued that his issuance of TCT No. T-2821 was a ministerial duty and that he had no involvement in the dismissal of the criminal case. He also claimed that he was denied due process during the IBP investigation.

  6. Death of Complainant
    During the proceedings, the complainant, Omar P. Ali, passed away. His daughter requested the withdrawal of the case, but the IBP and the Supreme Court ruled that disbarment proceedings are not terminated by the complainant’s desistance or death.

Issue:

  1. Whether Atty. Mosib A. Bubong may be disbarred for grave misconduct committed while he was a government official.
  2. Whether the withdrawal of the complaint by the complainant’s daughter affects the disbarment proceedings.
  3. Whether Atty. Bubong was denied due process during the IBP investigation.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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