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Reyes vs. Gaa, 246 SCRA 64

 A case digest of Reyes vs. Gaa, 246 SCRA 64, formatted for easy reference by law students:

Case Name: Reyes vs. Gaa

Citation: A.M. No. 1048. July 31, 1995 (246 SCRA 64)

Facts:

  • Wellington Reyes filed a disbarment case against his former lawyer, Atty. Salvador M. Gaa, a then-Assistant City Fiscal of Manila.
  • Reyes accused Atty. Gaa of extorting a total of P500.00 from him. Reyes was involved in an estafa case where Atty. Gaa was the investigating prosecutor.
  • The National Bureau of Investigation (NBI) set up an entrapment operation. Reyes gave Atty. Gaa marked money (P150.00), and Gaa was subsequently arrested. Traces of fluorescent powder from the marked bills were found on his hands.

Issue:

  • Whether or not Atty. Gaa's actions constitute gross misconduct and violation of his oath as an attorney, warranting disbarment.

Ruling:

The Supreme Court found Atty. Gaa guilty and ordered his disbarment. The Court ruled that:

  • The evidence overwhelmingly proved Atty. Gaa's guilt in the extortion scheme.
  • Extortion committed by a public official constitutes misconduct, which also violates a lawyer's oath.
  • Lawyers are bound by their oath to uphold integrity and to "delay no man for money or malice" (Rule 138, Section 20 of the Revised Rules of Court).

Penalty:

  • Atty. Salvador M. Gaa was disbarred. His name was stricken from the Roll of Attorneys.

Key Points for Law Students:

  • Professional Integrity: Lawyers are held to the highest standards of moral conduct, both in their roles as officers of the court and as private citizens.
  • Misconduct and Public Officials: Misconduct, especially when committed by a public official, reflects adversely on the legal profession as a whole.
  • Gravity of Extortion: Extortion is a serious crime that undermines the justice system. It represents a grave violation of a lawyer's oath.
  • Disbarment: Disbarment is the most severe penalty and signifies that the lawyer is unfit to continue practicing law.

Where to Find More Information:

Disclaimer: This case digest provides a simplified overview. Always consult with a qualified attorney and verify legal information for specific advice and the most current updates.

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Location: Davao City, Davao del Sur, Philippines

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