Title
Bengco vs. Bernardo
Case
A.C. No. 6368
Decision Date
Jun 13, 2012
A lawyer is suspended for one year and ordered to refund complainants for deceit and violations of the attorney's oath and professional conduct rules.
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Case Digest (A.C. No. 6368)

Facts:

  • Fidela G. Bengco and Teresita N. Bengco filed a disbarment complaint against Atty. Pablo S. Bernardo.
  • The events occurred between April 15, 1997, and July 22, 1997.
  • Atty. Bernardo, in collusion with Andres Magat, allegedly deceived the complainants into giving him ₱495,000.00.
  • He falsely claimed he would expedite the titling of land owned by the Miranda family in Tagaytay City.
  • Atty. Bernardo misrepresented himself as the lawyer for William Gatchalian, a prospective buyer, asserting he had connections with government agencies.
  • After receiving the money, he failed to fulfill his promise and misappropriated the funds for personal use.
  • The complainants filed a complaint for Estafa, leading to a finding of probable cause by the Third Municipal Circuit Trial Court.
  • Atty. Bernardo denied the allegations, claiming no involvement in the deceit.
  • The case was referred to the Integrated Bar of the Philippines (IBP) for investigation, which found sufficient evidence of misconduct.
  • The IBP initially recommended a two-year suspension, later modified by the IBP Board of Governors.
  • Atty. Bernardo filed a motion for reconsideration, arguing the complaint was filed beyond the two-year prescription period and denying any wrongdoing.
  • The IBP found he failed to comply with court orders and showed a lack of respect for the legal profession.

Issue:

  • (Unlock)

Ruling:

  • Yes, Atty. Pablo S. Bernardo committed deceit and malpractice, warranting disciplinary action.
  • No, the defense of prescription is not applicable to the administrative complaint against Atty. Bernardo.
  • Atty. Pablo S. Bernardo is suspended ...(Unlock)

Ratio:

  • The Supreme Court upheld the IBP's findings, stating Atty. Bernardo's actions constituted serious misconduct, including deceit and violation of his duties as a lawyer.
  • Administrative cases against lawyers do not prescribe, meaning the e...continue reading

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