In re Gonzales, 160 SCRA 771 (1988)

FACTS: Gonzales was the Tanodbayan or Special Prosecutor. He forwarded a letter-complaint to Justice
Fernan. The letter was said to be from concerned employees of the SC (an anonymous letter).
The letter was originally addressed to Gonzales referring to the charges for disbarment sought by Mr.
Miguel Cuenco against Justice Fernan, and asking him (Gonzales) to do something about it.
The Supreme Court furnished a copy to Gonzales, the per curiam Resolution of the SC, dismissing the
charges made by Cuencoagainst Justice Fernan for lack of merit. In that resolution, Cuencowas asked to
show cause why he should not be held administratively liable for making serious accusations against
Fernan.
ISSUE: Whether or not a Supreme Court justice can be disbarred during his term of office
RULING: A public officer (such as Justice Fernan) who under the Constitution is required to be a Member of
the Philippine Bar as a qualification for the office held by him and who may be removed from office only
by impeachment, cannot be charged with disbarment during the incumbency of such public officer.