Facts:

This case involves a verified complaint for disbarment filed by AA Total Learning Center for Young Achievers, Inc. (complainant), represented by Loyda L. Reyes, against Atty. Patrick A. Caronan (respondent) for alleged violations of the Code of Professional Responsibility. The events leading to the complaint began in 2012 when Caronan, along with Solly Cruz, represented themselves as agents of Maricel A. Atanacio, the rightful owner of a parcel of land in Ususan, Taguig City. Interested in acquiring the property for her institution's future campus, Reyes engaged in several meetings with Caronan, who claimed to have authority from Atanacio to negotiate the sale.

On March 9, 2012, Caronan conveyed to Reyes that Atanacio could not attend their meeting but had authorized him to negotiate a purchase price, ultimately agreeing to P15,650,000. Reyes made an earnest payment consisting of P100,000 in cash and P150,000 via check, which Caronan acknowledged. After additional payments,

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Facts:

Transaction Initiation and Representations

• In 2012, respondent Caronan, alongside Solly Cruz, offered to sell a parcel of land located on J.P. Rizal St. in Ususan, Taguig City to complainant Reyes, representing AA Total Learning Center for Young Achievers, Inc.
• Caronan and Cruz claimed to be representatives of Maricel A. Atanacio, purportedly the registered owner of the subject property, which prompted Reyes to conduct an ocular inspection.

Negotiations and Payment Arrangements

• On March 9, 2012, Caronan convened a meeting with Reyes (and initially Atanacio) to settle the purchase details; during the meeting, he informed Reyes that Atanacio would no longer join and had authorized him to finalize the price.
• Relying on Caronan’s representations, Reyes agreed to a purchase price of ₱15,650,000.00 (inclusive of transfer fees and capital gains tax) and remitted an earnest money deposit in two installments: an initial ₱100,000.00 followed by ₱150,000.00 (with partial payment by cash and check), all duly acknowledged by Caronan.

Execution of Sale Documents and Subsequent Transactions

• A subsequent meeting was arranged at Metrobank Fort Bonifacio for the signing of the Deed of Absolute Sale and the payment of the initial 50% of the purchase price.
• At the meeting, Caronan disclosed that Atanacio would not be present and presented a deed already bearing Atanacio’s signature.
• Caronan executed the Memorandum of Agreement on Atanacio’s behalf.
• As part of the payment process, Reyes issued a Metrobank Manager’s check of ₱7,000,000.00, which Caronan acknowledged; it was agreed that the remaining balance would be settled upon transfer of title.
• Concurrently, Reyes paid ₱450,000.00 to cover capital gains tax and transfer fees – ₱300,000.00 via check (which was encashed by Caronan) and ₱150,000.00 in cash.

Discovery of Fraud and Misrepresentation

• On April 13, 2012, Reyes was notified of the negotiation of the ₱7,000,000.00 check, only to later learn that Caronan had misrepresented his authority after Atanacio disowned any involvement in the sale.
• In a subsequent meeting on July 19, 2012, when Reyes pressed for an explanation regarding the delay in the transfer of the title, Atanacio denied any form of authorization or participation in the transaction.
• Alarmed by these developments, Reyes, through legal counsel, issued a demand for the return of the total amount paid (₱7,700,000.00) after uncovering that Caronan, along with Noraida Tanon, had fraudulently negotiated the check by impersonating Atanacio using fake identification cards. This facilitated Caronan’s appropriation of the funds: withdrawal of ₱2,000,000.00 and deposit of ₱5,000,000.00 into his wife’s account.
• Further investigation revealed that Caronan had assumed the identity of his brother, Patrick A. Caronan, utilizing his credentials to obtain a law degree, which added to the gravity of his misconduct.

Filing of Criminal and Administrative Complaints

• On November 22, 2012, following these revelations, complainant AA (through Reyes) filed a criminal case for estafa against Caronan.
• Additionally, Reyes filed a Verified Complaint before the Integrated Bar of the Philippines (IBP) Commission on Bar Discipline, charging Caronan with gross misconduct and violations of the Code of Professional Responsibility, calling for his permanent disbarment and removal from the Roll of Attorneys.
• Caronan countered these allegations by asserting they were retaliatory actions by the Spouses Reyes, motivated by the criminal cases he had previously filed against them, and challenged the evidence regarding the fraudulent negotiation of the check. He also claimed that issues regarding his identity had been previously resolved in earlier cases.

IBP Investigation and Prior Disciplinary Findings

• The IBP’s Investigating Commissioner, Ferdinand I. DiAo, in his Report and Recommendation dated July 14, 2017, recommended dismissing the Verified Complaint on grounds of mootness in light of the Supreme Court’s decision in A.C. No. 11316 (July 12, 2016), which had already resolved issues concerning respondent’s gross dishonesty and false assumption of another’s identity.
• The IBP’s Board of Governors subsequently adopted the Investigating Commissioner’s findings with a modification recommending the imposition of ultimate disbarment and removal from the Roll of Attorneys.
• The resolution in the present case ultimately referenced these findings and previous disciplinary actions, noting that the matter should be declared closed and terminated.

Issue:

• Whether respondent Caronan’s acts of misrepresentation and fraud in the sale transaction, including the fraudulent negotiation of the check, constitute grounds for disbarment despite the existence of prior disciplinary findings.

• Whether the prior ruling in A.C. No. 11316, which already imposed penalties and addressed the misconduct related to false assumption of identity, renders the current disbarment complaint moot.

• Whether the administrative framework and disciplinary proceedings of the IBP allow for separate action on the issues raised herein, notwithstanding concurrent criminal and civil cases involving similar allegations.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)