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FERNANDO T. COLLANTES v. ATTY. VICENTE C. RENOMERON

FACTS:

The complaint for disbarment against Attorney Vicente Renomeron is related to an administrative case filed by Attorney Fernando Collantes. Collantes alleged that Renomeron neglected or refused to act on the registration of 163 Deeds of Absolute Sale with Assignment and the corresponding transfer certificates of titles to the GSIS without sufficient justification. Collantes accused Renomeron of conduct unbecoming of a public official, dishonesty, extortion, directly receiving pecuniary or material benefit, causing undue injury with manifest partiality, evident bad faith or gross inexcusable negligence, and gross ignorance of the law and procedure.

V & G Better Homes Subdivision, Inc. (V & G) requested the registration of deeds of sale with assignment on January 15, 1987. Despite repeated requests and compliance with requirements, Renomeron did not take any action on the application. Instead, he suspended the registration and demanded a "special arrangement" with V & G. The arrangement included providing Renomeron with a weekly round trip ticket from Tacloban to Manila and pocket money, or alternatively, selling Renomeron's Quezon City house and lot. On May 19, 1987, Renomeron informed Collantes that he would act favorably on the registration if certain conditions were met. Collantes sent the plane fare of P800, but Renomeron imposed additional requirements when he did not receive pocket money. When Collantes challenged Renomeron to act on all pending applications within 24 hours, Renomeron denied the registration of the transfer of 163 certificates of title to GSIS, citing ambiguity in the deeds of absolute sale with assignment. Collantes filed for reconsideration, noting that similar documents had been consistently registered in the past. Despite a ruling from the NLTDRA stating that the documents were registrable, Renomeron continued to delay the registration process. Collantes subsequently filed administrative charges against Renomeron with the NLTDRA. Renomeron denied the charges of extortion and directly receiving pecuniary or material benefit. Both parties submitted the case for resolution based on the pleadings, and the charges of dishonesty, causing undue injury, and gross ignorance of the law were recommended to be dropped.

ISSUES:

  1. Whether the respondent Register of Deeds neglected or refused to act on the registration of the 163 Deeds of Absolute Sale.

  2. Whether the respondent engaged in conduct unbecoming of a public official.

  3. Whether the respondent was guilty of dishonesty.

  4. Whether the respondent committed extortion.

  5. Whether the respondent directly received pecuniary or material benefit for himself in connection with the pending official transaction.

  6. Whether the respondent caused undue injury to a party through manifest partiality, evident bad faith, or gross inexcusable negligence.

  7. Whether the respondent was grossly ignorant of the law and procedure.

RULING:

  1. The investigator recommended dropping the charges of dishonesty, causing undue injury to a party through manifest partiality, evident bad faith or gross inexcusable negligence, and gross ignorance of the law and procedure. The charges of neglecting or refusing to act on the registration of the documents involved, in order to extort some pecuniary or material benefit from the interested party, were found to be absorbed by the charge of conduct unbecoming of a public official, extortion, and directly receiving pecuniary or material benefit for himself in connection with the pending official transaction. The case was submitted for resolution based on the pleadings.

PRINCIPLES:

  • Public officials should act promptly and without undue delay in performing their official duties.

  • Public officials should conduct themselves in a manner befitting their position and should not engage in conduct unbecoming of a public official.

  • Public officials should not engage in dishonesty or acts of extortion.

  • Public officials should not directly receive pecuniary or material benefit for themselves in connection with pending official transactions.

  • Public officials should not cause undue injury to a party through manifest partiality, evident bad faith, or gross inexcusable negligence.

  • Public officials should have the necessary knowledge of the law and procedure applicable to their duties.