Case Digest (A.C. No. 5050)
Facts:
The case involves Felisa M. Angeles, Celerina M. Angeles, Aurelia A. See, Maximo M. Angeles, Luisa A. Castro, and Loreto M. Angeles as complainants against Atty. Roberto L. Figueroa, the respondent. The complaint-affidavit was filed in April 1999, alleging that Atty. Figueroa used falsified registry receipts in his pleadings. The complainants were defendants in Civil Case No. 93-67503, which was pending before the Regional Trial Court, Branch 46, Manila, where Atty. Figueroa represented the plaintiffs, Bartolome M. Angeles, et al. On September 25, 1998, the trial court ordered Atty. Figueroa to file an answer to the complainants' request for admission. After multiple failures to comply, he submitted a manifestation on February 1, 1999, claiming he had sent his answer via registered mail and possessed registry receipt numbers 799, 800, and 801 from the Tanza Post Office. However, upon investigation by the complainants, it was revealed that these receipts were not posted at...
Case Digest (A.C. No. 5050)
Facts:
Background of the Case:
- Complainants (Felisa M. Angeles, Celerina M. Angeles, Aurelia A. See, Maximo M. Angeles, Luisa A. Castro, and Loreto M. Angeles) were defendants in Civil Case No. 93-67503 before the Regional Trial Court (RTC), Branch 46, Manila.
- Respondent, Atty. Roberto L. Figueroa, was the counsel for the plaintiffs (Bartolome M. Angeles, et al.) in the same case.
Allegations Against Respondent:
- On September 25, 1998, the trial court ordered respondent to file an answer to the complainants' request for admission.
- Respondent failed to file the answer multiple times and later filed a manifestation on February 1, 1999, claiming he had sent the answer via registered mail, supported by registry receipt nos. 799, 800, and 801 issued by the Tanza Post Office on November 16, 1998.
- Complainants and the court did not receive the alleged answer. Complainants investigated the matter and discovered that the registry receipts were not recorded or posted at the Tanza Post Office, as confirmed by the Postmaster of Tanza, Cavite, in a letter dated February 24, 1999.
Contempt of Court:
- Complainants filed a motion to declare respondent and his clients in contempt of court. The trial court granted the motion on March 26, 1999, fining respondent P2,000.00 for dishonesty and misconduct.
Complainants' Claims:
- Respondent's use of falsified registry receipts was intended to mislead the court and the opposing parties, constituting malpractice and violations of the Code of Professional Responsibility (Rule 1.01, Canon 10, Rule 10.01, and Rule 10.03).
- The act degraded the administration of justice and warranted disbarment or suspension under Section 27, Rule 138 of the Rules of Court.
Respondent's Defense:
- Respondent claimed he was unaware of the anomalies at the Tanza Post Office, where the registry receipts were issued but not recorded due to irregularities committed by the former postmaster, Mercedita Victa.
- He asserted that his father mailed the pleadings and received the registry receipts in good faith, and he should not be held liable for the post office's misconduct.
Issue:
- Whether respondent Atty. Roberto L. Figueroa used falsified registry receipts to mislead the court and the opposing parties.
- Whether respondent's actions constitute grounds for disbarment or suspension under the Code of Professional Responsibility and the Rules of Court.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court dismissed the administrative complaint against Atty. Roberto L. Figueroa, finding no sufficient evidence to support the allegations of misconduct. The Court emphasized the importance of clear and convincing proof in disciplinary cases and upheld the principle that lawyers should not be penalized for acts beyond their control.