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In re: Delos Angeles, 106 Phil.1

 A case digest of In re: Dalmacio Delos Angeles (106 Phil. 1), presented in a manner suitable as a reference for law students:

Case Name: In re: Dalmacio Delos Angeles

Citation: 106 Phil. 1 (1959)

Key Areas of Law:

  • Legal Ethics
  • Disbarment
  • Moral Turpitude

Facts:

  • Atty. Dalmacio Delos Angeles was convicted by the Court of Appeals of the crime of attempted bribery.
  • He was sentenced to two years, four months, and one day of destierro (banishment) and a fine.
  • The Supreme Court required him to show cause as to why he should not be disbarred from practicing law.

Issues:

  • Whether an attorney convicted of a crime involving moral turpitude should be disbarred.

Holding:

  • Yes. The Supreme Court held that conviction of a crime involving moral turpitude is a ground for disbarment.

Reasoning:

  • Moral Turpitude: The Court defined moral turpitude as "anything that is done contrary to justice, honesty, modesty, or good morals". Bribery inherently involves moral turpitude.
  • Maintaining Public Trust: The continued possession of good moral character is a necessary qualification for the practice of law. When an attorney's actions demonstrate a lack of moral character, it damages the public's trust in the legal profession.
  • Rule 127, Section 25: This rule of the Rules of Court specifically states that a member of the bar may be removed as an attorney for the conviction of a crime involving moral turpitude.

Significance for Law Students:

  • Character over Competence: This case highlights that ethical conduct and good moral character are paramount for attorneys. Technical legal skills alone are insufficient.
  • Conviction as Grounds: Conviction of crimes involving moral turpitude will almost always result in disbarment, regardless of the specific circumstances of the crime.
  • Duty to Uphold the Profession: Lawyers have an ongoing responsibility to uphold the integrity of the legal profession as a whole. Individual acts of dishonesty or immorality impact the reputation of all attorneys.

Additional Notes

  • In his plea to the Court, the attorney appealed to the Court's sympathy based on his family responsibilities. The Court rejected this, emphasizing the seriousness of his transgression.
  • This case serves as a strong reminder of the high standards of conduct to which members of the legal profession are held.
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