Facts:

This case involves a complaint filed by Concordia B. Garcia against Atty. Crisanto L. Francisco, with the intention of seeking his disbarment. The complaint was lodged on October 6, 1992. The background of the dispute traces back to a lease agreement dated May 1, 1964, involving Garcia and her husband, Godofredo, along with the Dionisio spouses and Felisa and Magdalena Baetiong, who leased a parcel of land to Sotero Baluyot Lee for a duration of 25 years. After the lease period expired, Lee refused to vacate the property, claiming he had an extension option for an additional five years and a right of pre-emption over the land. The complainant alleged that Lee's attorney, Francisco, employed various legal maneuvers to hinder Garcia's attempts to reclaim her property, all of which were unfavorable to Lee. The case involved multiple litigations centered around the lease agreement and the rights of the parties, leading to accusations of forum shopping on Francisco's part

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Facts:

Background of the Dispute

• Concordia B. Garcia, together with her husband Godofredo and co-lessors Felisa and Magdalena Baetiong, leased a parcel of land to Sotero Baluyot Lee for 25 years beginning May 1, 1964.
• Upon expiration of the lease, Lee refused to vacate the property, claiming that he possessed an option to extend the lease for an additional five years and the right of pre-emption over the property.

Alleged Misconduct by Counsel

• On October 6, 1992, Garcia filed a sworn complaint before the court seeking the disbarment of Atty. Crisanto L. Francisco, who had been representing Lee in various proceedings.
• Garcia alleged that Francisco repeatedly instituted actions with the purpose of thwarting her right to regain possession of the property, thereby engaging in forum shopping.

Sequence of Judicial Proceedings Involved

• March 29, 1989 – Action for Specific Performance and Reconveyance:
• Filed by Lee through Francisco in the Regional Trial Court (RTC) of Quezon City as Civil Case No. Q-89-2118.
• Garcia filed a motion to dismiss on grounds including failure to state a cause of action, laches, and prescription.
• The case was dismissed on August 10, 1989, by Judge Felimon Mendoza.

Summary of Allegations

• Francisco was charged with grossly abusing his right to recourse by continuously engaging in multiple lawsuits and motions that had been consistently denied by the courts.
• His actions led to unnecessary congestion of judicial dockets, wasted judicial resources, and imposed additional inconvenience and expense on Garcia.
• The court found that Francisco’s conduct amounted to a deliberate misuse of judicial processes and a blatant disregard of his ethical obligations as a lawyer.

Issue:

Whether Atty. Crisanto L. Francisco’s repeated filings before different courts constituted forum shopping and an abuse of his right to recourse.

• Did the multiple actions pursued by Francisco involve the same parties, issues, and underlying lease contract, thereby flouting the prohibition against forum shopping?
• Whether such repeated petitions and legal maneuvers were aimed more at harassing the complainant rather than genuinely defending his client’s rights.

Whether Francisco’s conduct amounted to a violation of the ethical standards enshrined in the Code of Professional Responsibility.

• Was his strategy of filing numerous actions, many of which were improper or without merit, indicative of a wilful attempt to delay justice?
• Did his actions reflect a disregard for the duty of fidelity to the cause of justice expected of a lawyer?

• The appropriate sanction for a lawyer found to have abused the judicial process and disdained his ethical obligations.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)