May 4, 2006
FACTS: Respondent Atty. Carmelita Bautista-Lozada was formerly found guilty of violating Rules 15.03 and 16.04 of the Code of Professional Responsibility and of willfully disobeying a final and executory decision of the Court of Appeals. She was suspended from the practice of law for two years.
ISSUES: a. Whether or not the administrative complaint is barred by prescription?
b. Whether or not Rule VIII, Section 1 of the Rules of Procedure of the CBD-IBP is valid?
Moreover, assuming that prescription is a valid defense, respondent raised it only at this late stage. We presume she was familiar with that rule yet she failed to invoke it at the earliest opportunity. Instead she opted to insist on her innocence.
Rule VIII, Section 1 of the Rules of Procedure of the Commission on Bar Discipline of the Integrated Bar of the Philippines is hereby declared null and void.