A.C. No. 7181 - Angalan vs. Delante

Complainants: Maria Angalan, Nena Angalan, Dionicio Angalan, Magdalena Angalan, Francisca Angalan, Inis Angalan, Rosalino Angalan, and Josefina Angalan, all heirs of Angalan Samal and Sanaan Samal.
Respondent: Atty. Leonido C. Delante, a lawyer engaged in the dispute.
Subject Property: A 9.102-hectare parcel of land in Barrio San Jose, Kaputian, Island Garden City of Samal, Davao del Norte, originally covered by OCT No. P-11499.

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.
Complainants, being illiterate members of the Samal Tribe, affixed thumb marks on a document presented by the Spouses Eustaquio.

Complainants discovered that the document they signed was a deed of absolute sale, not a genuine mortgage.
Navarro R. Eustaquio subsequently transferred the title of the mortgaged property to his name, leading to the cancellation of OCT No. P-11499 and the issuance of TCT No. T-9926.

Complainants engaged the services of respondent to recover their property from the Spouses Eustaquio.
A receipt dated 18 November 1970 indicates that respondent acknowledged receiving P1,200 from Francisca Angalan and Macario Capul as full payment for his professional services regarding the recovery of the title.
Respondent filed a complaint with the then Court of First Instance claiming that the original patentees (Angalan and his children) had the right to repurchase the property under the Public Land Law.

An amicable settlement was reached on 3 September 1977 between complainants and the Spouses Eustaquio, wherein the complainants agreed to repurchase the property for P30,000.
According to the settlement, an initial payment of P15,000 was to be made with the balance paid later, and the Deed of Reconveyance was to be executed upon simultaneous payment.
However, complainants could not gather the P30,000 repurchase price, and respondent advanced the sum on their behalf, taking possession of the property and its produce as security.

Respondent, in a letter dated 10 January 1979, proclaimed that the heirs had redeemed the property through him and authorized Macario Capul to manage its produce.
When complainants later attempted to satisfy the repurchase price and reclaim the property, respondent refused.
Subsequently, respondent transferred the title from TCT No. T-9926 to his own name, issuing TCT No. T-57932.
In his answer and subsequent position paper, respondent claimed that complainants never engaged his services and alleged that his involvement was limited to advising on borrowing money.
Respondent also introduced an unsubstantiated narrative involving a New York client who purportedly bought the property, which was not corroborated by any documentary evidence.

Complainants filed a complaint with the RTC (Civil Case No. 57-2004) seeking void declarations of the deed of sale and TCT No. T-57932, and damages against respondent.
Respondent's alleged misconduct led to a complaint for gross violation of the Code of Professional Responsibility filed on 28 December 2005.
The Integrated Bar of the Philippines (IBP) conducted an investigation and, through Commissioner Hababag’s report, found respondent in violation for transferring the property to his name without consent, demonstrating a breach of trust.
The IBP initially recommended a six-month suspension, later increased to one year, before forwarding the case for final action.
The Court, after reviewing conflicting evidence and gauging credibility, sided with the complainants' version of the facts, noting clear evidence of engagement and payment for legal services.

Whether respondent, Atty. Leonido C. Delante, committed gross misconduct by transferring the title of the property into his own name, thereby betraying the trust placed in him by the complainants.
Whether the actions of the respondent constituted a violation of Canons 16 and 17 of the Code of Professional Responsibility by failing to hold in trust the property of his clients and by acting against their expressed instructions.
Whether respondent’s claim that his legal services were never engaged as alleged by him is credible in light of the evidence presented, including the receipt for professional fees and his actions on behalf of the complainants.