G.R. No. 205539 - Cruz vs. Spouses Christensen

In May 1996, Elmer Abastillas, playing coach of the Ozamis City volleyball team, requested financial assistance of P10,000 from Mayor Benjamin A. Fuentes of Ozamis City.
Mayor Fuentes approved and directed the City Treasurer to process the disbursement.
Mayor Fuentes designated city council member Mario R. Ferraren as Officer-in-Charge (OIC) while he was away.
Abastillas received the P10,000 assistance for the volleyball team.

Respondent Atty. Rodolfo D. Pactolin, then a provincial board member, obtained a photocopy of Abastillas's letter.
On June 24, 1996, Pactolin filed a complaint with the Office of the Deputy Ombudsman-Mindanao against Ferraren for illegal disbursement, attaching a copy of a purportedly falsified letter indicating Ferraren (not Mayor Fuentes) approved the disbursement.

Ferraren filed a complaint with the Sandiganbayan against Pactolin for falsification of public documents (Criminal Case 25665).
On November 12, 2003, the Sandiganbayan found Pactolin guilty of falsification under Article 172 of the Revised Penal Code.
The penalty imposed was imprisonment from 2 years and 4 months to 4 years, 9 months and 10 days, plus accessory penalties and a fine of P5,000.
Pactolin appealed to the Supreme Court, which on May 20, 2008, affirmed the conviction in G.R. No. 161455.

The Supreme Court referred the case as an administrative complaint against Pactolin under Rule 139-B of the Rules of Court to the Integrated Bar of the Philippines (IBP) for appropriate disciplinary action.
Ferraren did not participate in the IBP proceedings; the IBP Board of Governors ultimately dismissed the case on October 9, 2010, citing insufficiency of evidence.

Whether the conviction by final judgment of a crime involving moral turpitude, specifically falsification of public documents, is a sufficient ground for disbarment under Section 27, Rule 138 of the Rules of Court.

Whether Atty. Rodolfo D. Pactolin should be disbarred following his conviction for falsification.