Nava II v.

Artuz AC 7253, Februrary 18, 2020

DOCTRINE: In this regard, the Court invites attention to A.M. No. 02-9-02-SC, entitled "Re: Automatic Conversion
of Some Administrative Cases Against Justices of the Court of Appeals and the Sandiganbayan; Judges of Regular
and Special Courts; and Court Officials Who are Lawyers as Disciplinary Proceedings Against Them Both as Such
Officials and as Members of the Philippine Bar" Under this rule, the administrative case against a judge for Grave
Misconduct, Dishonesty, and Falsification — which are also grounds for the disciplinary action against members
of the Bar - are automatically considered as disciplinary proceedings against him or her as a member of the Bar.

FACTS: Atty. Nava II filed a Petition for Disbarment against Prosecutor Artuz for violation of Canon 8 of the Code
of the CPR, and for Grave Misconduct and violation of Republic Act No. 6713, docketed as  A.C. No. 7253. During
the pendency of A.C. No. 7253, Artuz was appointed and subsequently took her Oath of Office as Presiding Judge
of the Municipal Trial Court.

In a Report and Recommendation, the OBC recommended that Judge Artuz be disbarred pursuant to A.M. No. 02-
9-02-SC for violation of the Code of Professional Responsibility. The OBC noted that Judge Artuz was already
found by the Court guilty of Grave Misconduct, Dishonesty, and Falsification of Official Documents for her false
statements in her two (2) Personal Data Sheet and for her willful defiance of Court directives, which findings, it
held, already constitute sufficient grounds to warrant her disbarment.

ISSUE:  Whether or not Judge Artuz should be disbarred.

RULING: Yes. The administrative case against a judge for Grave Misconduct, Dishonesty, and Falsification —
which are also grounds for the disciplinary action against members of the Bar - are automatically considered as
disciplinary proceedings against him or her as a member of the Bar. It cannot therefore be denied that Grave
Misconduct, Dishonesty, and Falsification of Official Documents constitute grounds to disbar an attorney. In Judge
Artuz's case, she was herein found to have committed all of these grounds warranting her immediate disbarment
as a consequence.