Facts:

This case involves a complaint filed by Maria Angalan, Nena Angalan, Dionicio Angalan, Magdalena Angalan, Francisca Angalan, Inis Angalan, Rosalino Angalan, and Josefina Angalan (collectively referred to as the complainants), against Atty. Leonido C. Delante (the respondent). The events leading to the complaint began in 1971 when the complainants, who are heirs of Angalan Samal and Sanaan Samal, borrowed P15,000 from Navarro R. Eustaquio and Arabella P. Eustaquio (the Spouses Eustaquio) to secure a loan against their 9.102-hectare property in Barrio San Jose, Kaputian, Island Garden City of Samal, Davao del Norte, covered by Original Certificate of Title (OCT) No. P-11499. The complainants, who are illiterate and belong to the Samal Tribe, were misled into signing a deed of absolute sale instead of a mortgage, resulting in the cancellation of their title and the issuance of Transfer Certificate of Title (TCT) No. T-9926 in the name of Navarro Eustaquio.

In their attempt to ...

Facts:

Background of the Complainants and the Property

• The complainants, Maria Angalan, Nena Angalan, Dionicio Angalan, Magdalena Angalan, Francisca Angalan, Inis Angalan, Rosalino Angalan, and Josefina Angalan, are the heirs of Angalan Samal and Sanaan Samal.
• They are illiterate and belong to the Samal Tribe.
• They owned a 9.102-hectare parcel of land in Barrio San Jose, Kaputian, Island Garden City of Samal, Davao del Norte, covered by Original Certificate of Title (OCT) No. P-11499.

Loan and Alleged Deed of Sale

• On 15 April 1971, Angalan and the complainants borrowed P15,000 from Navarro R. Eustaquio and Arabella P. Eustaquio (Spouses Eustaquio).
• To secure the loan, they mortgaged 8.102 hectares of the property and surrendered OCT No. P-11499 to the Spouses Eustaquio.
• The Spouses Eustaquio prepared a document, which the complainants signed with their thumb marks, believing it to be a mortgage agreement.
• Later, the complainants discovered that the document was a deed of absolute sale, and the property was transferred to Navarro Eustaquio under TCT No. T-9926.

Engagement of Respondent

• The complainants engaged the services of Atty. Leonido C. Delante (respondent) to recover their property.
• Respondent filed a complaint with the Court of First Instance (CFI) in 1976, seeking the reconveyance of the property.
• The parties entered into an amicable settlement in 1977, where the complainants agreed to repurchase the property for P30,000.
• Complainants did not have the funds, so respondent advanced the P30,000 and took possession of the property until he was repaid.

Respondent's Actions

• When the complainants tried to repay the P30,000 and recover the property, respondent refused.
• Complainants discovered that respondent had transferred the title of the property to his name under TCT No. T-57932.

Complaint and Proceedings

• Complainants filed a complaint with the RTC in 2004, seeking to declare the deed of sale and TCT No. T-57932 void and to recover damages.
• Respondent denied the allegations, claiming that a client from New York had bought the property and that he was merely holding it in trust.
• Complainants also filed a disbarment complaint against respondent for gross violation of the Code of Professional Responsibility.

Issue:

1. Whether respondent violated the Code of Professional Responsibility by acquiring the property of his clients without their knowledge and consent.
2. Whether respondent’s actions constitute gross misconduct warranting disbarment.

Ruling:

• The Court found respondent guilty of violating Canons 16 and 17 of the Code of Professional Responsibility.
• Respondent was disbarred from the practice of law, and his name was ordered to be stricken from the Roll of Attorneys.

Ratio:

1. Violation of Canon 16: Lawyers are required to hold in trust all properties of their clients that come into their possession. Respondent failed to do so by transferring the property to his name and refusing to return it to the complainants.
2. Violation of Canon 17: Lawyers must be mindful of the trust and confidence reposed in them by their clients. Respondent breached this trust by taking advantage of the complainants’ illiteracy and financial plight to acquire their property.
3. Gross Misconduct: Respondent’s actions constituted gross misconduct, which is a ground for disbarment under Section 27, Rule 138 of the Rules of Court.
4. Credibility of Respondent’s Defense: The Court found respondent’s defense (that a client from New York bought the property) to be unbelievable and unsupported by evidence.
5. Penalty: Given the gravity of respondent’s offense, the Court imposed the ultimate penalty of disbarment to maintain the integrity of the legal profession.