A.C. No. 6281 - Miranda vs. Carpio

On September 26, 2011, the Court issued a decision suspending Atty. Macario D. Carpio for six (6) months and ordering him to return to Complainant Valentin C. Miranda the owner’s duplicate copy of Original Certificate of Title No. 0-94.
The suspension was imposed after finding that Respondent unjustly retained the Owner’s Duplicate Copy to coerce Complainant into agreeing to an exorbitant attorney’s fee.

On November 28, 2013, the Court received a letter from Complainant indicating that Atty. Carpio still had not complied with the order to return the document.
In response, and upon the Court’s directive, Respondent filed his Explanation/Compliance/Motion to Lift Order of Suspension dated October 28, 2014.

Based on the findings and the Report and recommendation of the Office of the Bar Confidant, the Court issued another resolution on January 15, 2020.
The subsequent resolution again suspended Atty. Carpio for an additional six (6) months and reiterated the directive to return the Owner’s Duplicate Copy.

Respondent claimed that he attempted to deliver the document on July 23, 2018 at the Complainant’s address but could not locate him.
He later attributed his failure to return the document to his diagnosis of prostate cancer, subsequent surgery, and being bedridden, asserting that these circumstances rendered him incapable of personally delivering the document.
To demonstrate good faith, Respondent, through his counsel/daughter, Atty. Christine P. Carpio-Aldeguer, stated that he was surrendering the duplicate copy to the Court for safekeeping until an authorized representative of Complainant’s heirs is determined.
However, Respondent did not attach the physical document in his recent submission, and his counsel questioned the evidentiary value of a letter received from the widow of the deceased Complainant, Blecilda D. Miranda.

The Court received Blecilda’s unsinged letter dated December 12, 2019, informing it of Respondent’s continued defiance.
A subsequent Resolution dated June 8, 2020 ordered Respondent to file a comment regarding the letter, which was later submitted on December 15, 2020, along with an unsigned letter from Blecilda.
The Court also noted that copies of its resolutions were furnished to various offices, including the Office of the Bar Confidant, the Integrated Bar of the Philippines, and the Office of the Court Administrator, to ensure wider circulatory information.

Respondent’s repeated failure to comply with clear court orders over a period spanning more than 10 years, including the initial directive in 2011, forms a central element in the case.
The Court emphasized that the obligation to return the Owner’s Duplicate Copy was directed solely at Respondent and could not be shifted to the Complainant.

Whether Atty. Carpio’s failure to return the Owner’s Duplicate Copy constitutes willful disobedience of the Court’s orders.
Whether his arguments related to advanced age, illness, and post-surgical complications provide sufficient justification or excuse for non-compliance.

Whether the unsigned letter from Blecilda D. Miranda, Complainant’s widow, undermines or affects the veracity of the allegations of non-compliance.
Whether the application of technical rules of procedure and evidence in this administrative disciplinary proceeding should be strictly enforced.

Whether the cumulative failure to comply with the Court’s directive over an extended period justifies the imposition of a harsher penalty, namely indefinite suspension.
Whether the Court’s reliance on Section 27, Rule 138 of the Revised Rules of Court and Canon 11 of the Code of Professional Responsibility is properly supported by the facts of the case.