Case Digest (A.C. No. 11316)
Facts:
Complainant Patrick A. Caronan and respondent Richard A. Caronan a.k.a. “Atty. Patrick A. Caronan” are brothers born to Porferio R. Caronan, Jr. and Norma A. Caronan. Patrick was born on August 5, 1976, graduated from Makati High School in 1993, obtained a Business Administration degree from the University of Makati in 1997, and pursued a career with Philippine Seven Corporation (PSC), rising to Store Manager by 2009. Richard, born February 7, 1975, attended Pamantasan ng Lungsod ng Maynila and briefly the Philippine Military Academy, but never earned a college degree. In 2004, their mother informed Patrick that Richard had enrolled in St. Mary’s University College of Law in Bayombong, Nueva Vizcaya using Patrick’s name and academic records, and purportedly passed the Bar examinations. Patrick later discovered “Atty. Patrick A. Caronan” certificates displayed in Richard’s Taguig office and endured repeated misidentifications by third parties, investigations by the NBI in 2009, aCase Digest (A.C. No. 11316)
Facts:
- Complainant and respondent backgrounds
- Complainant Patrick A. Caronan
- Born August 5, 1976 to Porferio R. Caronan, Jr. and Norma A. Caronan.
- Graduated Makati High School (1993); B.S. Business Administration at University of Makati (1997).
- Employed by Philippine Seven Corporation (7-11) rising to Store Manager (2009); married with two daughters.
- Respondent Richard A. Caronan a.k.a. “Atty. Patrick A. Caronan”
- Born February 7, 1975; graduated Makati High School (1991).
- Attended Pamantasan ng Lungsod ng Maynila (1991–1992) and Philippine Military Academy (1992–1993) without degree; thereafter engaged in family business; relocated to Nueva Vizcaya.
- Discovery of identity assumption and ensuing controversies
- Unauthorized use of complainant’s identity
- Informed in 2004 that respondent passed the Bar using complainant’s name and college records at St. Mary’s University College of Law, Bayombong.
- In 2006, complainant saw “Patrick A. Caronan” on a Certificate of Admission to the Bar at respondent’s office.
- May 2009 NBI investigation: complainant produced high school records, university transcripts, driver’s licenses, law school submissions, alumni book photo.
- Adverse consequences to complainant
- Related complaints: qualified theft/estafa by Agtarap; misrepresentations to law offices, church members, and Mrs. Reyes in land sale; respondent’s arrests for gun-running, explosives, BP 22 violations.
- Complainant feared for safety, suffered reputational harm among colleagues, and resigned from PSC.
- October 2013: filed Complaint-Affidavit before IBP Commission on Bar Discipline to stop respondent’s false representation and illegal practice of law.
- Proceedings before the IBP and Supreme Court
- IBP-CBD conferences (2015): both parties failed to appear; no position papers filed.
- June 15, 2015 IBP Investigating Commissioner’s Report: found respondent guilty of false identity assumption; recommended dropping “Patrick A. Caronan” from the Roll and barring “Richard A. Caronan” from future admission.
- June 30, 2015 IBP Board of Governors Resolution No. XXI-2015-607 adopting the recommendation.
- Appeal to the Supreme Court; issues certified.
Issues:
- Whether the IBP erred in ordering that the name “Patrick A. Caronan” be stricken off the Roll of Attorneys.
- Whether the IBP erred in ordering that the name “Richard A. Caronan” be barred from being admitted to the Bar.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)