G.R. No. 110068 - Philippine Duplicators, Inc. vs. National Labor Relations Commission

The Court, in its decision promulgated on January 23, 2018, found respondent Atty. Anastacio E. Revilla, Jr. guilty of violating the Code of Professional Responsibility.
The violation stemmed from committing fraud against his client, as evidenced by breaches of:

In view of the respondent’s continuing disbarment, the penalty imposed was a fine amounting to P100,000.00.
The decision was declared immediately executory and orders were issued to disseminate copies of the decision to:

The Office of the Court Administrator for national circulation,
The Integrated Bar of the Philippines, and
The Office of the Bar Confidant for encoding in the respondent’s personal record.

The respondent filed a motion seeking to reduce the fine from P100,000.00 to P50,000.00.
In support of his motion, the respondent presented the following justifications:

He has been experiencing significant financial constraints following his disbarment rendered on December 4, 2009 (A.C. No. 7054).
He suffers from chronic kidney disease, which requires him to undergo dialysis treatments three times a week.
His disbarment resulted in the loss of his sole source of livelihood.
He has candidly acknowledged his ethical missteps and expressed sincere remorse.

Mitigating factors—such as a respondent’s acknowledgment of their infractions, demonstrable remorse, family and humanitarian considerations, and other circumstantial factors—can justify a lighter sanction.
The decision emphasized that judicial discretion in disciplinary cases allows for the imposition of penalties that are less severe when mitigating circumstances are present.

This precedent provided the legal basis to consider the mitigating factors raised by the respondent in his motion.

Whether the disciplinary decision, imposing a fine of P100,000.00 on Atty. Revilla for ethical violations, should be modified in light of the respondent’s mitigating circumstances.
Whether the substantial financial hardship and medical condition (chronic kidney disease requiring frequent dialysis) of the respondent justify a reduction in the prescribed penalty.
How the judicial considerations and prior administrative cases regarding mitigating factors, such as those outlined in Arganosa-Maniego v. Salinas, apply to the circumstances of the present case.