Facts:

The case revolves around Atty. Luis V. Artiaga, Jr. as the complainant and Atty. Enrique C. Villanueva as the respondent, with the Supreme Court of the Philippines deliberating on the matter in A.C. No. 1892, decided on July 29, 1988. The controversy began with a sworn complaint filed by Artiaga against Villanueva on April 2, 1978, accusing him of engaging in unethical practices. Following the filing of the complaint, the Supreme Court ordered Villanueva to respond, which he did on July 5, 1978. Artiaga subsequently provided a reply on July 31, 1978. Upon review of the submissions, the Court referred the matter to the Solicitor General for a thorough investigation, who submitted a report on May 4, 1988, concluding that Villanueva was guilty of misconduct, particularly for causing his client to commit perjury and lacking respect for the courts.

The case involved multiple legal disputes concerning properties tied to a client of Artiaga, Juliano Estolano, and clients of Villanueva,

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Facts:

Background of the Complaint and Proceedings

• On April 2, 1978, Atty. Luis V. Artiaga, Jr. filed a sworn complaint with the Supreme Court seeking the disbarment of Atty. Enrique C. Villanueva for alleged unethical practices.
• The Court, by resolution dated May 24, 1978, ordered respondent Atty. Villanueva to answer the complaint.
• Atty. Villanueva answered on July 5, 1978, and Atty. Artiaga, Jr. filed his reply on July 31, 1978.
• The Court subsequently referred the case to the Solicitor General for investigation and received his Report and Recommendation on May 4, 1988, which found respondent guilty of misconduct and recommended his suspension for at least six (6) months.

Factual Background of the Underlying Litigation

• The complaint for disbarment arose from four separate cases and several incidental cases involving the same property, wherein Juliano Estolano was the client of Atty. Artiaga, Jr. and Glicerio Aquino/Florentina Guanzon were clients of Atty. Villanueva.
• The factual matrix is drawn from the decision in the Court of Appeals (CA-G.R. No. Sp-06600, November 16, 1977) involving:
• Three contiguous parcels of land in Bambang, Los Baños, Laguna with differing titles and disputed boundaries.
• The issuance of Certificate of Title No. P-286 to petitioner Estolano for one parcel, and subsequent disputes relating to the other parcels involving Revocable Permit Applications by various parties.
• Multiple transactions, transfers, and permit applications occurring between 1950 and 1958, leading to conflicting claims among Estolano, Aquino, and Guanzon.
• Subsequent adjudicatory proceedings included:
• Conflicts heard and decided by the Bureau of Lands and later modified by the Director of Lands in orders dated May 21, 1962, and August 13, 1962.
• Appeals to higher authorities including the Secretary of Agriculture and Natural Resources and resolution by the Office of the President affirming decisions.
• Parallel actions on the property:
• A forcible entry case (Civil Case No. 192) involving Aquino and Guanzon against Estolano, which resulted in conflicting orders and eventual non-compliance with an Order of Execution.
• Additional cases filed for annulment of title (Civil Case No. 179-C, later CA-G.R. No. 62576-R) and a complaint filed with the Court of Agrarian Relations (CAR Case No. 7043) that further complicated the litigation over the disputed property.
• Actions by Atty. Villanueva in relation to these cases included:
• Alleged involvement in inducing his client to perjure testimony regarding the dispossession dates to manipulate jurisdiction over a forcible entry case.
• Filing of multiple, seemingly dilatory and unmeritorious cases aimed at forestalling rightful enforcement of judicial orders and obstructing the administration of justice.

Acts Constituting the Alleged Misconduct

• Causing his client, Glicerio Aquino, to contradict the factual timeline (alleging dispossession in 1960 in the original complaint versus June 1973 in the amended complaint) to secure the court’s jurisdiction.
• Demonstrating a lack of candor and respect toward both the courts and his adversaries by:
• Filing an urgent ex-parte motion for clarification in a forcible entry case while simultaneously perfecting an appeal.
• Engaging in delaying tactics such as multiple appeals and filing subsequent cases even after certain orders became final.
• Filing additional legal actions:
• Initiating a case for annulment of Estolano’s title despite clear grounds of res judicata and prescription.
• Filing a case before the Court of Agrarian Relations without disclosing previous related litigation, resulting in a restraining order that hindered the enforcement of a judicial decision.
• Alleged criminal complaint filing against Estolano and his client for violating P.D. 316 and a restraining order, which was later dismissed, further evidence of his questionable tactics.

Issue:

Whether Atty. Enrique C. Villanueva engaged in unethical practices such as:

• Inducing his client to commit perjury by altering factual assertions regarding the date of dispossession.
• Demonstrating a lack of candor and respect towards the courts and his adversaries by deliberately manipulating procedural rules.

Whether the respondent’s conduct amounted to an abuse of his right of recourse to the courts, notably:

• The filing of multiple petitions and appeals, including cases already dismissed or rendered moot, to delay or obstruct rightful judicial processes.
• The use of dilatory and forum-shopping tactics which congest the court dockets and undermine the administration of justice.

• Whether such conduct by an attorney, who is sworn to uphold the truth and aid in the administration of justice, justifies disciplinary action, specifically suspension from the practice of law.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)