Title
Balistoy vs. Bron
Case
A.C. No. 8667
Decision Date
Feb 3, 2016
A disbarment complaint against Atty. Bron for allegedly using falsified CTCs and medical certificates was dismissed due to lack of evidence, but he was reprimanded for lack of due care in notarizing documents.
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Case Digest (A.C. No. 8667)

Facts:

Background of the Case:

  • Inocencio I. Balistoy (Balistoy) filed a disbarment complaint against Atty. Florencio A. Bron (Atty. Bron) before the Office of the Bar Confidant (OBC).
  • Balistoy was the plaintiff in Civil Case No. 03-105743, a damages case against Paul L. Wee and Peter L. Wee, where Atty. Bron represented the defendants.

Discrepancies in Community Tax Certificates (CTCs):

  • Atty. Bron filed a Motion to Dismiss and Motion for Issuance of Order to Show Cause with Counterclaim on March 5, 2003, on behalf of the Wee brothers.
  • The Wee brothers presented CTCs for verification, but Balistoy discovered discrepancies in the CTCs:
    • Paul Wee’s CTC No. 12249877 was issued in Quezon City on January 9, 2003, but the same number appeared in a CTC issued in Manila on January 20, 2004.
    • Peter Wee’s CTC No. 1385810 was issued in Manila on January 29, 2003, but the same number appeared in a CTC issued in Manila on January 20, 2004.
  • Balistoy verified with the Manila Treasurer and the Bureau of Internal Revenue (BIR) in Quezon City, which confirmed that the CTCs were not issued by the City of Manila in 2003 and were instead issued to Taguig and Pampanga.

Non-Appearance at Hearings:

  • On September 6, 2006, Atty. Bron and his clients failed to appear at a hearing. Atty. Bron claimed that Paul Wee had suffered injuries in a vehicular accident and submitted an unsigned medical certificate.
  • On June 20, 2007, Atty. Bron moved for a resetting of the hearing, claiming that Paul Wee had arrived from Malaysia with a fever and was under quarantine. He submitted a medical certificate, which Balistoy later discovered was not issued by the NAIA.

Balistoy’s Complaint:

  • Balistoy filed a disbarment complaint against Atty. Bron, alleging that Atty. Bron knowingly used falsified CTCs and medical certificates, committed deceit, gross misconduct, and violated notarial rules.

Atty. Bron’s Defense:

  • Atty. Bron denied any knowledge of the falsified CTCs and medical certificates. He claimed that he acted in good faith and had no opportunity to verify the authenticity of the documents.
  • He argued that the notarial rules Balistoy cited took effect in August 2004, while the notarization in question occurred in 2003 and January 2004.
  • Atty. Bron also claimed that Balistoy’s complaint was retaliatory and lacked sufficient evidence.

Issue:

  1. Whether Atty. Bron violated the rules on notarization by notarizing documents with falsified CTCs.
  2. Whether Atty. Bron committed gross misconduct by submitting falsified medical certificates to the court.
  3. Whether Atty. Bron should be disbarred for his alleged actions.

Ruling:

The Supreme Court denied Balistoy’s petition and dismissed the disbarment complaint against Atty. Bron for lack of merit. However, Atty. Bron was reprimanded for his lack of due care in notarizing the motion to dismiss and the answer in the civil case.

Ratio:

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