G.R. No. 72335-39 - Tatad vs. Sandiganbayan

Virgilio J. Mapalad, Sr. (complainant) filed a verified Complaint for disbarment dated October 16, 2009 against Atty. Anselmo S. Echanez (respondent) before the Integrated Bar of the Philippines (IBP).
The complaint arose from respondent’s alleged misrepresentation of his Mandatory Continuing Legal Education (MCLE) compliance.

In Civil Case No. 1635-1-784 before the Municipal Trial Court in Santiago City, Isabela, respondent served as counsel for the defendants, while complainant was one of the plaintiffs.
After the trial court's decision favoring plaintiffs, respondent filed a Notice of Appeal dated May 22, 2009, wherein he indicated his MCLE Compliance No. II-0014038 but did not specify the date of issuance.
Respondent also filed the appellants’ brief in the same case, again only indicating the MCLE Compliance Number without the date.
In Special Civil Action No. 3573, respondent filed a Petition for Injunction for the same clients, indicating only the MCLE Compliance Number.
Respondent additionally filed a Motion for Leave of Court dated July 13, 2009, again citing the MCLE compliance number without a date of issue.
Upon inquiry with the MCLE Office, complainant discovered respondent had no recorded MCLE compliance. The MCLE Office issued a certification dated September 30, 2009, confirming respondent had not complied with the MCLE requirements for the first (April 15, 2001 to April 14, 2004) and second compliance periods (April 15, 2004 to April 14, 2007).

Complainant argued respondent’s act constituted serious malpractice and grave misconduct, deliberately misleading courts and parties regarding his MCLE compliance.
Complainant prayed for respondent’s disbarment.
The Supreme Court issued a February 10, 2010 resolution requiring respondent to file a comment within 10 days, but respondent failed to comply.
A second resolution dated July 11, 2011 required respondent to show cause why he should not be disciplined or held in contempt, which was also ignored by respondent.
The IBP Commission on Bar Discipline (IBP-CBD) issued a Notice of Mandatory Conference/Hearing on August 14, 2013, but neither party appeared.
Only complainant filed a position paper reiterating his allegations.
After investigation, the IBP-CBD Investigating Commissioner recommended disbarment of respondent in a report dated December 17, 2013.
On September 28, 2014, the IBP Board of Governors adopted the recommendation, citing respondent’s violation of the Lawyer's Oath, Code of Professional Responsibility (CPR) Canons, use of falsified MCLE compliance number, failure to obey orders, and prior sanctions.
No motion for reconsideration was filed by either party.

Whether respondent Anselmo S. Echanez should be administratively disciplined for:

Falsely representing MCLE compliance by indicating a false MCLE Compliance Number in pleadings;
Misleading courts, clients, and fellow counsels by such misrepresentation; and
Repeatedly failing to comply with court orders and IBP directives.