Piatt v Abordo

Facts:
On Feb. 19, 1932, Abordo, a member of the Philippine Bar, accepted the
offer of two unnamed individuals to sell him a quantity of opium (a
prohibited drug), and agreed to pay P1.50 per tin.
In the same afternoon, he was picked up at the corner of Taft Avenue
extension and Vito Cruz in Manila, by one of the offerors and was taken
to the Rizal Ave. Ext. where they found a number of persons waiting for
them in an automobile. The transaction occurred, and he paid Php600 to
a Cabrales for a can of what he believed was opium.
On his way back to the city, his automobile was cutoff and overtaken by
another vehicle whose parties were pretending to be members of the
Philippine Constabulary. They told Abordo to stop, but instead, he took
out his revolver and told his driver to turn into Calle Vito Cruz was able
to evade his pursuers and to arrive safely at his home in Pasay.
Upon arriving there, he opened and checked the can he bought and
found that the contents were fake opium and sand.
He reported to the Luneta Police Station of Manila that he had been
robbed of P600. Two individuals were later arrested, charged with the
crime of estafa, and convicted.
Abordo admitted that he entered into the transaction, adding that "he is
sincerely sorry for it and vows not to repeat."
He argues that the acts he committed could not affect his status as
attorney-at-law and could not constitute a ground for disciplinary action
because:
o There is no evidence in the record establishing an attorney-client
relationship between him and the opium vendors
o The transaction was not committed in the exercise of his profession of
attorney-at-law
Issue: WoN the actions of Abordo could serve as grounds for a disciplinary
action by the SC YES
Although Sec. 21 of the Code of Civil Procedure enumerates the grounds
for suspension or disbarment, a lawyer can be suspended or removed
from office based on other statutory grounds
General rule: The Court will not assume jurisdiction to discipline one of
its officers for misconduct alleged to be committed in his private
capacity.
o Exception: An attorney will be removed not only for malpractice and
dishonesty in his profession, but also for gross misconduct not
connected with his professional duties, which show him to be unfit for
the office and unworthy of the privileges which his license and the law
confer upon him.

In this case, Abordos act was in direct contravention of the

Criminal Law of the Philippines, even though it was not
consummated.