A.C. No. 4934 - Aquino vs. Villamar-Mangaoang

Complainant Daniel S. Aquino, formerly a Special Investigator of the Legal and Investigation Staff of the Bureau of Customs at NAIA, was assigned to a unit headed by the respondent, Atty. Maria Lourdes Villamar-Mangaoang.

On July 2, 1996, a passenger, Christopher B. Gomez, arrived at NAIA from San Francisco, California (Flight No. PR-105). During the x-ray screening of one of his balikbayan boxes, images resembling handgun parts were observed.

A subsequent examination by Customs Examiner Manolito Ermita confirmed the presence of assorted gun parts, prompting the filing of a criminal complaint against Gomez by the DOJ Prosecution Task Force.

It is alleged that on or during the preliminary investigation—specifically on September 2, 1996—respondent, together with Customs Police Officer Apolonio Bustos, ordered the transfer of the gun parts from Gomez’s balikbayan box to another box.

Complainant asserts that respondent further directed Office Messenger Joseph Maniquis to deliver the modified balikbayan box (now devoid of gun parts) to the State Prosecutor, allegedly to benefit Gomez, a close friend of the respondent.

The alleged substitution of evidence is claimed to have resulted in the dismissal of the criminal charges against Gomez.

In her Answer, respondent denied ever having ordered the switching of boxes, asserting that she did not have control over the physical disposition of the evidence.

Respondent also emphasized the delay in the filing of the complaint—over two years after the dismissal of charges—as indicative of the unfounded nature of the accusations.

The complaint was investigated by the Integrated Bar of the Philippines (IBP), which ultimately recommended dismissal for lack of merit on March 4, 2003.

A key piece of evidence was the affidavit of Office Messenger Joseph P. Maniquis (dated August 5, 1998), claiming that respondent had instigated, planned, and supervised the substitution of Gomez’s balikbayan box.

Maniquis later executed a Sinumpaang Salaysay that recanted his prior affidavit, thereby undermining the earlier statement.

Additional documentary evidence, such as the office attendance logbook for September 2, 1996, indicated that respondent was absent from the office during the critical period.

Customs Police Officer Apolonio Bustos and other officers (Edgardo R. Galang and Juan B. Turqueza) provided statements contradicting the complainant’s account, including denials of ordering or participating in the movement of the evidence.

Whether respondent, Atty. Maria Lourdes Villamar-Mangaoang, actually ordered or participated in the substitution of evidence related to Christopher Gomez’s balikbayan box.
Whether the actions (if any) of the respondent constitute dishonesty, legal impropriety, or a breach of her duties as a lawyer, court officer, and public official.
Whether the complainant met the burden of proving his allegations by clear, convincing, and satisfactory evidence required in disbarment proceedings.
Whether any alleged misconduct, assuming it occurred, resulted in actual damage or prejudice to the government.