Facts:

On June 3, 1983, Leandro Ayroso filed a Sinumpaang Salaysay against Attorney Arsenio R. Reyes, alleging a violation of the lawyer's oath. The complaint resulted from a series of legal actions instigated against Ayroso by Reyes' clients, which Ayroso claimed were groundless. These cases included various criminal charges such as perjury, malicious mischief, and falsification of public documents—all filed by Gaudencio Ayroso, Maximo Manalo, Ernesto Manalo, and Moises Manalo. The incidents began with a perjury charge (Crim. Case No. 2703) regarding a certification that the land Ayroso purchased was not tenanted, which led to his acquittal on June 21, 1982. Subsequently, Ayroso was charged with malicious mischief in two separate instances, with convictions in the Municipal Court that were later overturned on appeal. Other cases included civil suits for possession of property and further criminal charges of falsification and malicious mischief, all of which culminated in vario

...

Facts:

Background of the Complaint

• On June 3, 1983, Leandro Ayroso, a resident of Gapan, Nueva Ecija, filed a Sinumpaang Salaysay charging Attorney Arsenio R. Reyes with having violated his lawyer’s oath.
• The complaint alleged that Attorney Reyes had instigated or induced the filing of numerous cases against Ayroso, despite the charges being groundless in nature.
• The case was referred to the Solicitor General for an investigation into the complaint.

The Cases Cited in the Complaint

• Case No. 2703 (Perjury)
• Charged by Gaudencio Ayroso, Maximo Manalo, Ernesto Manalo, and Moises Manalo, who were clients of Attorney Reyes.
• The charge involved an affidavit falsely certifying that land purchased by Ayroso was not tenanted, when it actually was.
• On June 21, 1982, the trial court acquitted Ayroso of the perjury charge.
• Malicious Mischief Charges
• First charge: Crim. Case No. 5528 at the Municipal Court of Gapan for allegedly destroying ricefield dikes filed by Gaudencio Ayroso, Ernesto Manalo, Maximo Manalo, and Moises Manalo; conviction ensued followed by an appeal and subsequent acquittal on January 14, 1983 (Crim. Case No. 1347).
• Second charge: Crim. Case No. 152-81 filed by Ernesto Manalo for alleged destruction of a ricefield dike; eventually dismissed on November 17, 1981.
• Third charge: Crim. Case No. 2182 in which Ayroso was again charged with malicious mischief but was acquitted by the Court of First Instance.
• Fourth charge: Crim. Case No. 220-82 filed by Moises Manalo on September 23, 1982 for alleged destruction of a ricefield dike.
• Other Criminal and Civil Cases
• A civil case (No. 1260) filed on July 24, 1979 by Gaudencio Ayroso, seeking recovery of Lot H-6 purchased by Leandro Ayroso from Victor Ayroso.
• A criminal charge of Falsification of Public Document filed by Gaudencio Ayroso against Leandro Ayroso.
• A charge of Kidnapping and Illegal Detention (Crim. Case No. 2162) later substituted by a charge of Grave Coercion, where Ayroso was acquitted.
• A charge of Falsification (I.S. No. 1-83-55) filed against Ayroso’s brothers—Emeterio, Aurelio, and Gregorio—by Gaudencio Ayroso in Cabanatuan City.

Relationship and Prior Cases

• The complainant and respondent were acquainted since childhood in Gapan, Nueva Ecija.
• Attorney Reyes had represented several of the complainant's relatives and adverse parties in various disputes.
• The respondent contended that the present administrative complaint was a retaliatory measure for previous legal defeats suffered by Ayroso, cited as follows:
• Civil Case No. 999 for partition and damages, which was dismissed after Ayroso was ordered to implead all co-owners.
• A libel case filed by Ayroso against his uncle Gaudencio Ayroso, later dismissed by the fiscal.
• A complaint before the Municipal Accident Report (MAR) wherein Ayroso was ordered to recognize Ernesto Manalo as the tiller of the land.
• A charge of arson (Crim. Case No. CCC-IV-55 [81]) against multiple defendants including Gaudencio Ayroso and the Manalos, resulting in acquittal.
• A robbery case (Crim. Case No. 183-80) filed on July 3, 1980, against several individuals, which was dismissed by the Municipal Court of Gapan.

Solicitor General’s Report and Findings

• The Solicitor General was tasked with investigating the allegations.
• On May 17, 1988, his report concluded that there was no direct evidence to substantiate the claim that Attorney Reyes instigated or induced the filing of the numerous cases.
• The report emphasized that Reyes’s role as counsel for adverse parties did not equate to any wrongful instigation on his part.

Issue:

• Whether Attorney Arsenio R. Reyes, by virtue of being the counsel of adverse parties in all the cases filed against Leandro Ayroso, violated his lawyer’s oath by allegedly instigating or inducing the filing of these cases.
• Whether the mere appearance of a lawyer as counsel for parties on the opposing side constitutes evidence of any wrongful instigation, regardless of the eventual dismissal or acquittal of the cases.
• Whether the evidence, including the Solicitor General’s report, sufficiently established a causal link between Attorney Reyes’s representation and the filing of the said cases.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)