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...

Facts:

Parties and Background

• Complainants: Felisa M. Angeles, Celerina M. Angeles, Aurelia A. See, Maximo M. Angeles, Luisa A. Castro, and Loreto M. Angeles.
• Respondent: Atty. Roberto L. Figueroa.
• Underlying civil litigation: The incident stems from actions during Civil Case No. 93-67503 pending before the Regional Trial Court, Branch 46, Manila, where complainants were defendants and respondent represented plaintiffs (Bartolome M. Angeles, et al.).

Sequence of Events

• On September 25, 1998, the trial court ordered respondent to file an answer to a request for admission.
• Respondent, after several failures to file the answer timely, submitted a manifestation dated February 1, 1999 claiming that his answer had been dispatched through registered mail using registry receipt numbers 799, 800, and 801, all purportedly issued on November 16, 1998, by the Tanza Post Office in Cavite.
• The non-receipt of the answer by both the complainants and the court prompted them to initiate an inquiry at the Central Post Office in Lawton, Manila.

Investigation and Evidence Regarding Postal Anomalies

• Tomas Baggay of the Inspection Service of the Philippine Postal Corporation informed the complainants that according to a letter-report from the Tanza Post Office (dated February 24, 1999), the receipts bearing numbers 799, 800, and 801 were not actually posted—only other letters (receipts No. 1566 to 1577) were sent.
• Complainants subsequently filed a motion to declare respondent (and Bartolome M. Angeles, et al.) in contempt of court.
• The trial court, on March 26, 1999, found respondent in contempt and imposed a fine of P2,000.00, basing its finding on what it perceived as respondent’s use of falsified postal receipts.

Evidence Submitted by the Parties

• Complainants’ evidence:
• A copy of respondent’s Answer to the Request for Admission dated November 16, 1998.
• A copy of the February 1, 1999, manifestation by respondent.
• The trial court's Order dated February 25, 1999, and the contempt Order dated March 26, 1999.
• Letters from postal officials, including the report by Tomas Baggay and the letter from former Tanza Postmaster Josefino A. Arbolante.
• The motion by complainants seeking contempt findings.
• Respondent’s evidence and explanation:
• Asserts that he dispatched the pleadings via registered mail from the Tanza Post Office on November 16, 1998, relying on the receipts issued in good faith.
• Explains his reliance on his late father to handle the mailing and that he could not be held accountable for anomalies committed by the post office, notably due to irregularities under former Postmaster Mercedita Victa, including the non-remittance of fees and irregular posting of receipts.
• Emphasizes that he did not alter or manufacture the receipts and was unaware of any misconduct until the post office anomalies came to light.

Administrative Proceedings and Subsequent Hearings

• The case was referred to the Office of the Bar Confidant (OBC) for evaluation.
• The OBC’s first report, submitted on December 8, 2003, recommended dismissal of the complaint for lack of merit.
• The case was re-referred for a full-blown hearing on February 4, 2004, and further evidence and testimony were collected, including eyewitness accounts on postal anomalies (e.g., testimony from Josefino A. Arbolante and Luzvimindo Layva).
• On June 16, 2005, following a comprehensive investigation and hearing, the OBC submitted a report reaffirming that the evidence supported dismissal of the complaint against respondent.

Issue:

Whether Atty. Roberto L. Figueroa deliberately used falsified registry receipts to mislead the court and parties in Civil Case No. 93-67503.

• Does the submission of the registry receipts, which were later found not to have been posted, constitute intentional misconduct or fraudulent behavior on the part of the respondent?

Whether the evidence presented by the complainants is sufficient to establish a clear, convincing, and satisfactory proof of misconduct on the part of respondent.

• Can the non-posting of the receipts be attributed to deliberate deception by the respondent or to irregularities in postal operations beyond his control?

Whether the disciplinary actions recommended (disbarment or suspension) are appropriate given the circumstances and evidence, considering the standards prescribed by the Code of Professional Responsibility and Rules of Court.

• Is the imposition of a contempt finding and the subsequent call for severe sanctions justified based on the available facts?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)