FACTS:

Complainant Alex Nulada filed a verified complaint for disbarment against Atty. Orlando S. Paulma for dishonesty and conviction of a crime involving moral turpitude. Complainant alleged that on September 30, 2005, respondent issued him a check in the amount of P650,000.00 as payment for a debt. However, when complainant presented the check for payment, it was dishonored due to insufficient funds. Despite notice of dishonor and repeated demands, respondent failed to make good the amount of the check. As a result, complainant filed a criminal complaint for violation of Batas Pambansa Bilang (BP) 22 against respondent. The Office of the Provincial Prosecutor issued a resolution recommending the filing of the appropriate information against respondent. After due proceedings, the Municipal Trial Court (MTC) rendered a decision finding respondent guilty of violation of BP 22 and ordering him to pay a fine. Respondent appealed his conviction to the Regional Trial Court (RTC), but the RTC affirmed the MTC ruling. The RTC decision became final and executory on April 16, 2009. Complainant filed an administrative complaint against respondent prior to the promulgation of the RTC decision. Respondent denied committing dishonesty and claimed that he informed complainant about the insufficiency of funds prior to issuing the check. He argued that he issued the check only to accommodate a friend from whom he obtained the loan. The Court referred the administrative case to the Integrated Bar of the Philippines (IBP) for investigation. The IBP's Commission on Bar Discipline (CBD) issued a report recommending respondent's suspension for six months. The IBP Board of Governors later adopted this recommendation with modification, suspending respondent from the practice of law for two years. The issue before the Court is whether or not respondent should be administratively disciplined for having been found guilty of a crime involving moral turpitude.

ISSUES:

RULING:

1. The Court agrees with the findings and recommendations of the IBP that the offense for which respondent was found guilty of, i.e., violation of BP 22, is a crime involving moral turpitude. The Court also agrees that respondent violated his lawyer's oath and the Code of Professional Responsibility (CPR) by committing the said offense. The Court emphasized the importance of the lawyer's oath and held that by his conviction of the said crime, respondent has shown that he is "unfit to protect the administration of justice or that he is no longer of good moral character" which justifies his suspension from the practice of law. Therefore, respondent is administratively disciplined and suspended from the practice of law for a period of two (2) years.

PRINCIPLES:

• Conviction of a crime involving moral turpitude may justify administrative discipline against a lawyer.

• A lawyer's conviction of a crime involving moral turpitude is a violation of the lawyer's oath and the Code of Professional Responsibility (CPR).

• The lawyer's oath is significant as it ensures the lawyer's fitness to protect the administration of justice and maintain good moral character.