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	AC. No. 8708 2015-08-12	SPS. BYRON AND MARIA LUISA SAUNDERS v. ATTY. LYSSA GRACE S. PAGANO-CALDE SERENO, C.J.
Disbarment proceeding is separate and distinct from a criminal action filed against a lawyer even if they involve the same set of facts.[9] A finding of guilt in the criminal case will not necessarily result in a finding of liability in the administrative case. Conversely, the acquittal does not necessarily exculpate one administratively.[10]
	AC. No. 10132 2015-03-24	HEIRS OF PEDRO ALILANO v. ATTY. ROBERTO E. EXAMEN VILLARAMA, JR., J.
This ruling was reiterated in the more recent case of Bengco v. Bernardo,[26] where the Court stated that putting a prescriptive period on administrative cases involving members of the bar would only serve to embolden them to disregard the very oath they took as lawyers, prescinding from the fact that as long as no private complainant would immediately come forward, they stand a chance of being completely exonerated from whatever administrative liability they ought to answer for.