FACTS:

The case involves a joint petition for review filed by Atty. Levi P. Muñoz in connection with complaints for disbarment filed against him by Arthur O. Monares, Atty. Oliver O. Olaybal, and Benjilieh M. Constante. Monares filed a civil case against Ludolfo Muñoz and alleged that Atty. Levi Muñoz represented his brother during regular government hours while employed as the Provincial Legal Officer of Albay City. Olaybal, as the chairman of ALECO's old board of directors, engaged Muñoz as retained counsel. Olaybal claimed that Muñoz did not inform ALECO's old board that he was employed as Provicial Legal Officer and that Muñoz illegally collected payments in excess of what was agreed upon in their retainer agreement. Constante claimed that Muñoz filed cases against Sunwest Construction and Development Corporation while he was serving as Provincial Legal Officer.

The complainants sought Muñoz's disbarment for unlawfully engaging in private practice and for acts of disloyalty. The complaints were referred to the Integrated Bar of the Philippines for investigation, and Commissioner Aguila recommended that Muñoz be found guilty of gross misconduct. The IBP Board of Governors approved and adopted the recommendation, imposing a penalty of suspension for four years.

Muñoz filed an appeal for mercy and clemency, which was denied. Muñoz then filed an appeal before the Supreme Court, requesting a reduction of the recommended penalty or dismissal of the complaints against him. The Court remanded the appeal to the IBP, and the IBP Board of Governors reduced the recommended period of suspension to three years.

ISSUES:

1. The main issue in this case is whether or not Atty. Levi P. Muñoz should be disbarred for unlawfully engaging in private practice and for acts of disloyalty.

RULING:

1. The IBP-BOG recommended that Atty. Levi P. Muñoz be found guilty of gross misconduct and violation of the Code of Professional Responsibility (CPR) and be suspended from the practice of law for an aggregate period of four (4) years. On automatic review, the IBP-BOG approved and adopted the recommendation. However, on appeal, the IBP-BOG reduced the recommended period of suspension to three (3) years.

PRINCIPLES:

• Lawyers are prohibited from engaging in private practice if it involves conflict of interest or violation of the rules of professional ethics. (Violation of Rules 1.01, 6.02, 15.01, and 15.03 of the CPR)

• Authorities from government officials granting lawyers permission to engage in private practice must be clear and unambiguous, and any violation of the restrictions imposed may lead to the cancellation or revocation of such authority.