A.C. No. 12486 - Genato vs. Mallari

Complainant Antonio X. Genato invested ₱18 million in an allegedly 133-hectare property in San Fernando, Pampanga, represented by Atty. Eligio P. Mallari as owner by prior judgment.
Genato discovered the land belonged to the Philippine National Bank (PNB) and was subject to land reform distribution. His criminal estafa complaint against Mallari was dismissed and is under DOJ review.

In Eligio P. Mallari v. GSIS and Provincial Sheriff (G.R. No. 157659), Mallari allegedly used dilatory tactics to evade a final executory decision for 24 years, prompting a CBD investigation.
On October 29, 2012, Mallari published ads challenging CA Justice Bruselas to a “public and televised debate” over a PNB-related decision, flouting Section 20, Rule 138, RRC.
In G.R. No. 157660 (Mallari v. Banco Filipino), he allegedly ignored and obstructed enforcement of a writ of possession after losing in court.
He filed baseless harassment suits against PNB lawyers and the Pampanga Register of Deeds, all dismissed, demonstrating a modus operandi of vexatious filings.

Mallari’s Verified Answer denied all charges, claiming he merely defended proprietary rights and was himself harassed by Genato.
The Investigating Commissioner found violations of Canons 1, 10, 11, 12 (Rules 1.02, 10.03, 11.05, 12.04) and Section 20, Rule 138, and recommended six months’ suspension.
The IBP Board of Governors adopted the findings and recommended two successive six-month suspensions.
The Supreme Court, en banc, adopted the factual findings but held Mallari guilty of gross misconduct and disbarred him, ordering his name stricken from the Roll of Attorneys.

Did Mallari’s conduct in multiple cases (GSIS, Banco Filipino, public debate challenge, frivolous suits) breach the Code of Professional Responsibility and Lawyer’s Oath?
Did his actions amount to willful disobedience of lawful court orders and disrespect for judicial authority?

Given the gravity and repetition of misconduct, should Mallari be suspended or disbarred?