G.R. No. 195987 - Province of Pampanga vs. Romulo

The Integrated Bar of the Philippines (IBP) Board of Governors, then composed of petitioners Jose Anselmo I. Cadiz, Leonard S. De Vera, Romulo A. Rivera, Dante G. Ilaya, Pura Angelica Y. Santiago, Rosario T. Setias-Reyes, Jose Vicente B. Salazar, Manuel M. Monzon, Immanuel L. Sodusta, and Carlos L. Valdez, Jr., along with Lydia A. Navarro, handled the complaint.
An administrative complaint was filed on February 23, 2003 by Lilia T. Ventura and Concepcion Tabang against respondent Atty. Glenn C. Gacott alleging gross misconduct, deceit, and gross dishonesty.

The IBP Board designated Lydia A. Navarro as Commissioner to investigate the allegations against Atty. Gacott.
Commissioner Navarro summoned the parties to a mandatory conference and required the submission of position papers by the parties.
Relying on the position papers and affidavits submitted by witnesses, Commissioner Navarro prepared her Report and Recommendation for the IBP Board.

The IBP Board adopted Commissioner Navarro’s findings from her report.
Although Navarro initially recommended a penalty of six months suspension from law practice, the IBP Board increased the recommended penalty to disbarment before transmitting the report to the Supreme Court.

On September 29, 2004, the Supreme Court remanded the case back to the IBP Board for further proceedings.
The Court emphasized that considering the gravity of the charge against Atty. Gacott, the investigating commissioner should have subpoenaed and examined the witnesses instead of relying solely on the position papers and affidavits.

While the IBP Board was still complying with the remand order for additional proceedings, Atty. Gacott filed a complaint for damages against the board’s sitting members before the Regional Trial Court (RTC) of Puerto Princesa City, Palawan.
In response, the IBP Board filed an answer raising the affirmative defense that the complaint failed to state a cause of action and subsequently moved to dismiss the case on that ground.
On March 9, 2006, the RTC denied the motion to dismiss, leading the IBP Board to elevate the case to the Court of Appeals (CA) on a special civil action for certiorari.
The CA, on December 29, 2006, denied the petition, ruling that the RTC did not commit grave abuse of discretion; it further noted that the IBP Board had alternative plain and speedy remedies, such as proceeding to trial and appealing if needed.
After the CA denied a motion for reconsideration in its Resolution dated July 12, 2007, the IBP Board petitioned the Supreme Court, which eventually granted the petition.

Whether the Supreme Court’s remand of the disbarment case to the IBP Board—due to the lack of an exhaustive hearing—constitutes a basis for Atty. Gacott to claim damages against the members of the IBP Board of Governors.

Whether the IBP Board and its designated Commissioner, in relying solely on position papers and affidavits instead of conducting an exhaustive hearing, exceeded their delegated investigatory powers.
Whether the discretionary power provided to the investigating commissioner and the Board to determine the necessity of a clarificatory or full-blown hearing can shield them from liability in damages for purported procedural errors.
Whether holding the IBP Board liable for honest errors in performing their quasi-judicial functions would open the floodgates for damage suits against other judicial officers.