Title
IN RE: Disbarment Proceedings vs. Jaramillo
Case
Adm. Case No. 229
Decision Date
Apr 30, 1957
A lawyer convicted of estafa, a crime involving moral turpitude, was disbarred despite claims of judicial error and excessive punishment, as the final conviction rendered him unfit for the legal profession.

Case Summary (Adm. Case No. 229)

Background of the Conviction

Narciso N. Jaramillo was convicted of estafa by the Court of First Instance of Pangasinan. Subsequently, his conviction was upheld on appeal by the Court of Appeals on April 17, 1954, which imposed an indeterminate penalty ranging from two months and one day of arresto mayor to one year and one day of prision correccional. This criminal conviction directly influenced the disbarment proceedings against him.

Filing of the Disbarment Complaint

While Jaramillo was serving his sentence for estafa, the Solicitor General filed a complaint for his disbarment with the Supreme Court on August 5, 1955. This action was prompted by the serious nature of the crime which raised concerns about Jaramillo's fitness to be a member of the legal profession.

Respondent’s Arguments

In his defense, Jaramillo contended that his conviction stemmed from judicial error, asserting that the trial court did not adequately consider his explanation regarding the financial loss associated with the case. He claimed that the psychological and emotional toll of his imprisonment constituted sufficient punitive measures, arguing that disbarment would be excessively harsh.

Legal Principles and Moral Turpitude

The Court emphasized that estafa is a crime involving moral turpitude, which fundamentally impacts an attorney's professional standing. The nature of the offense reflects adversely on an individual's honesty and integrity, traits essential for upholding the dignity of the legal profession.

Finality of Conviction and Impact on Disbarment Proceedings

The Court noted that the validity of Jaramillo's conviction was no longer subject to review, as the judgment had become final and executed. This finality underscored the Court's position that it was not necessary to entertain extensive arguments regarding his moral character

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