Facts: As early as January 15, 1987, V & G had requested the respondent Register of Deeds to register some 163 deeds of sale with assignment of lots of the V & G mortgaged to GSIS by the lot buyers. There was no action from the respondent. Although V & G complied with the desired requirements, respondent Renomeron suspended the registration of the documents pending compliance by V & G with a certain “special arrangement” between them. Fed up with the respondent’s extortionate tactics, the complainant wrote him a letter on May 20, 1987 challenging him to act on all pending applications for registration of V & G within twenty-four (24) hours. On May 22, 1987, respondent formally denied registration of the transfer of 163 certificates of title to the GSIS on the uniform ground that the deeds of absolute sale with assignment were ambiguous as to parties and subject matter. On May 27, 1987, respondent elevated the matter en consulta to the Administrator, Land Registration Authority [LRA]. Exasperated by respondent’s conduct, the complainant filed with the NLTDRA on June 4, 1987 administrative charges against respondent Register of Deeds. LRA Administrator Teodoro G. Bonifacio on February 22, 1988, recommended to Secretary of Justice Sedfrey A. Ordoñez that the respondent: (1) be found guilty of simple neglect of duty: (2) be reprimanded to act with dispatch on documents presented to him for registration; and (3) be warned that a repetition of similar infraction will be dealt with more severely. After due investigation of the charges, Secretary Ordoñez found respondent guilty of grave misconduct, recommended to President Corazon C. Aquino that Renomeron be dismissed from the service, with forfeiture of leave credits and retirement benefits, and with prejudice to re-employment in the government service, effective immediately. Less than two weeks after filing his complaint against Renomeron in the NLTDRA, Attorney Collantes also filed in this Court on June 16, 1987, a disbarment complaint against said respondent.
Issue: Whether the respondent register of deeds, as a lawyer, may also be disciplined by this Court for his malfeasances as a public official.
Held: Yes, for his misconduct as a public official also constituted a violation of his lawyer’s oath. An oath imposes upon every lawyer the duty to delay no man for money or malice. The lawyer’s oath is a source of his obligations and its violation is a ground for his suspension, disbarment or other disciplinary action.
The Code of Professional Responsibility applies to lawyers in government service in the discharge of their official tasks (Canon 6). Just as the Code of Conduct and Ethical Standards for Public Officials requires public officials and employees to process documents and papers expeditiously (Sec. 5, subpars. [c] and [d] and prohibits them from directly or indirectly having a financial or material interest in any transaction requiring the approval of their office, and likewise bars them from soliciting gifts or anything of monetary value in the course of any transaction which may be affected by the functions of their office (See. 7, subpars. [a] and [d]), the Code of Professional Responsibility forbids a lawyer to engage in unlawful, dishonest, immoral or deceitful conduct (Rule 1.01, Code of Professional Responsibility), or delay any man’s cause “for any corrupt motive or interest” (Rule 103).