G.R. No. L-27454 - Chaves vs. Gonzales

Jennie Valeriano was a respondent in multiple cases for estafa and violation of Batas Pambansa Blg. 22, assigned to Joselito C. Barrozo, then Assistant Public Prosecutor of Dagupan City, Pangasinan.
Valeriano alleged that Barrozo demanded P20,000.00 to resolve these cases in her favor.

Valeriano reported Barrozo’s demand to the Office of the Regional State Prosecutor, who coordinated with the National Bureau of Investigation (NBI) for an entrapment operation.
On February 15, 2005, Barrozo was caught accepting the P20,000.00 from Valeriano during the operation.
A charge of direct bribery was filed against Barrozo before the Regional Trial Court of Dagupan City, later transferred to the Sandiganbayan as he held a position with a salary grade of 27 or higher.

On March 17, 2011, the Sandiganbayan found Barrozo guilty beyond reasonable doubt of direct bribery under Article 210, paragraph 2 of the Revised Penal Code.
Barrozo was sentenced to an indeterminate penalty of prision correccional maximum (four years, two months, one day) to prision mayor medium (nine years, four months, one day).
He was also fined P60,000.00 and subjected to special temporary disqualification.

Barrozo filed three motions for reconsideration and a Petition for Review on Certiorari with the Supreme Court, all of which were denied.
A final Entry of Judgment was issued on August 16, 2012.

In October 2013, a Hong Kong law firm reported to the Office of the Bar Confidant (OBC) that a letter was received signed by “Atty. Joselito C. Barrozo” regarding a claim for a domestic helper's long service payment.
The OBC verified that Barrozo had been convicted of direct bribery and learned he resigned from the Department of Justice effective May 3, 2005.
The Supreme Court, by Resolution dated December 11, 2013, required Barrozo to comment on why he should not be suspended or disbarred for his conviction.

Barrozo argued that signing the claim letter was not practicing law and involved no monetary consideration or lawyer-client relationship.
The OBC found this argument meritless and recommended disbarment in its February 20, 2015 Report and Recommendation.

Whether respondent Joselito C. Barrozo’s conviction for direct bribery involves moral turpitude, thus warranting suspension or disbarment from the practice of law.
Whether the respondent’s act of signing the claim letter after conviction constitutes unauthorized practice of law.
Whether the penalty of disbarment is proper under the circumstances of the case.