### Facts:
This legal case involves a verified petition for disbarment filed against Atty. Mosib Ali Bubong, stemming from his actions while serving as the Register of Deeds in Marawi City. The complaint originated from an administrative case accusing Bubong of illegal exaction, the indiscriminate issuance of a Transfer Certificate of Title (TCT), and manipulating a criminal complaint against certain individuals. The initial investigation by the Land Registration Authority (LRA) cleared Bubong of these charges. However, upon review, the Secretary of Justice found him guilty of grave misconduct regarding the issuance of the TCT and manipulating the criminal case, leading to his dismissal by an Administrative Order from President Fidel V. Ramos. Bubong contested this dismissal up to the Supreme Court, which affirmed the decision. Subsequently, a disbarment petition was filed before the Supreme Court based on these findings.
### Issues:
The critical issue before the Supreme Court was whether Bubong could be disbarred for misconduct committed while in government service, particularly whether his actions as Register of Deeds warranted disbarment as a violation of his professional duties as an attorney.
### Court’s Decision:
The Supreme Court resolved to disbar Atty. Mosib A. Bubong, affirming that the nature of his misconduct while serving in a governmental capacity directly impacted his qualifications and moral standing as a lawyer. The court held that Bubong’s actions in his capacity as Register of Deeds exhibited a grave abuse of his legal knowledge and position for personal interest, which significantly undermined public confidence in his office and the integrity of the legal profession.
### Doctrine:
The ruling reinforced the doctrine that the Code of Professional Responsibility applies to lawyers in government service in the discharge of their tasks, emphasizing Rule 6.02’s provision against using public positions to promote private interests. It established or reiterated that misconduct in a governmental role, if indicative of moral delinquency or violation of the lawyer’s oath, could form the basis for disciplinary action, including disbarment.
### Class Notes:
– **Key Elements for Disciplinary Action in Legal Profession**: A lawyer’s conduct in and out of public service must adhere to the ethical standards and the oath of the profession. Misconduct, showing moral delinquency, can lead to disbarment.
– **Critical Statutory Provision**: Code of Professional Responsibility, Rule 6.02 – Lawyers in public service must not use their position to advance private interests.
– **Application**: In cases of misconduct by a lawyer serving in a governmental role, the pivotal question is whether the actions demonstrate a violation of the ethical obligations and moral character expected of lawyers. The facts must show a breach significant enough to undermine confidence in the legal profession or contradict the fundamental duties of honesty, integrity, and fidelity to the law.
### Historical Background:
The context of this case sheds light on the stringent standards to which legal professionals, especially those serving in public office, are held. It underscores a consistent theme in Philippine jurisprudence regarding the importance of public confidence in the integrity of both governmental positions and the legal profession, highlighting that the duties and responsibilities of a lawyer do not pause upon entering public service.
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