Case Digest (A.C. No. 716)
Facts:
The case involves Eduardo J. Berenguer as the complainant and Pedro B. Carranza as the respondent. The events leading to the complaint began on July 15, 1966, when Berenguer filed a complaint against Carranza for allegedly deceiving the Court of First Instance of Sorsogon. The complaint centered around an Affidavit of Adjudication and Transfer executed by the mother of Carranza's client, which falsely stated that the deceased left no legitimate heirs except for the affiant. In reality, the deceased was survived by four daughters and a son, who was the father of the complainant. Carranza introduced this affidavit into evidence, despite being aware of its falsity.
In response to the complaint, Carranza filed an answer on August 17, 1966, claiming that he had no involvement in the preparation of the affidavit or the petition, which were prepared in Pasay City. The case was subsequently referred to the Solicitor General for investigation, where both parties were heard. The...
Case Digest (A.C. No. 716)
Facts:
- Complaint Filed: On July 15, 1966, Eduardo J. Berenguer filed a complaint against Pedro B. Carranza, a lawyer, for allegedly deceiving the Court of First Instance of Sorsogon.
- Allegation: Carranza introduced an Affidavit of Adjudication and Transfer in court, which falsely stated that the deceased left no legitimate heirs except the affiant (his client’s mother). In reality, the deceased was survived by four daughters and one son (the complainant’s father).
- Respondent’s Defense: Carranza claimed he had no hand in preparing the affidavit or the petition, as they were prepared in Pasay City. He argued that the affidavit was introduced only to prove the transfer of property to his client.
- Investigation: The case was referred to the Solicitor General, who found no evidence linking Carranza to the preparation of the false affidavit. However, the Solicitor General noted that Carranza failed to exercise due diligence in reviewing the affidavit, contributing to confusion and prolongation of the cadastral case.
Issue:
- Whether respondent Pedro B. Carranza violated his oath as a lawyer by consenting to or introducing false evidence in court.
- Whether Carranza’s failure to exercise due diligence in reviewing the affidavit constitutes a breach of his professional duties, even if the falsehood was not wilful.
Ruling:
The Supreme Court found respondent Pedro B. Carranza liable for failing to exercise due diligence as a lawyer. While there was no evidence of wilful deception, his failure to thoroughly review the affidavit and ensure its accuracy resulted in confusion and prolongation of the case. The Court reprimanded Carranza and warned that a repetition of such conduct would be dealt with more severely.
Ratio:
- (Unlock)