Case Digest (G.R. No. 196426)
Facts:
The case involves an administrative complaint filed by Atty. Marcos V. Prieto against respondents Judge Ferdinand A. Fe and Atty. Oscar B. Corpuz, both of whom are members of the Philippine bar. The events that led to the complaint date back to various civil cases involving Yolanda M. Roque and her mother, Salud Andrada Marquez, concerning disputes over properties that were the subject of foreclosure and subsequent litigation. On August 2, 1993, Marquez mortgaged six parcels of land to the Rural Bank of Luna, La Union, Inc., which later foreclosed due to defaults. In October 1996, Roque initiated a complaint (Civil Case No. 1081-BG) against the petitioner for a declaration of nullity of certain contracts relative to the properties; Judge Fe, then a lawyer, represented Roque and prepared the complaint. This case was eventually dismissed because Roque lacked standing at the time.
Upon her mother's death on August 9, 2002, Roque retained Atty. Corpuz to pursue the annulment ac
Case Digest (G.R. No. 196426)
Facts:
- Background of the Complaint
- Atty. Marcos V. Prieto, acting as complainant, filed an administrative complaint against:
- Respondent Judge Ferdinand A. Fe, for alleged dishonesty and serious misconduct prejudicial to the integrity and dignity of the Judiciary.
- Respondent Atty. Oscar B. Corpuz, as a member of the bar, for his role in the handling of related civil cases.
- The complaint was rooted in events arising from two civil cases:
- Civil Case No. 1081-BG: Yolanda M. Roque v. Atty. Marcos V. Prieto, et al.
- Civil Case No. 1518-BG: Yolanda Marquez Roque v. Atty. Marcos V. Prieto, et al.
- Allegations Raised by the Complainant
- Improper Access and Misuse of Documents
- Complainant alleged that respondent lawyer obtained free access to the records of Civil Case No. 1081-BG with the assistance of respondent Judge.
- It was claimed that the respondent lawyer was permitted to copy portions of the complaint from Civil Case No. 1081-BG, which could give him an undue advantage in Civil Case No. 1518-BG.
- Conflict of Interest and Misconduct by the Judge
- The complaint asserted that Civil Case No. 1518-BG was raffled to respondent Judge Fe, who was the former counsel of the plaintiff in Civil Case No. 1081-BG.
- It was further contended that certain paragraphs in the complaint in Civil Case No. 1518-BG were copied from the earlier complaint drafted by the respondent Judge when he was acting as a lawyer.
- Ethical Violations
- The alleged misconduct was said to constitute malice or wrongful intent rather than mere errors of judgment.
- The actions – including the copying of documents and subsequent signing by the respondent lawyer – were claimed to violate Rule 1.01, Canon 1 of the Code of Professional Responsibility by undermining the integrity and independence of the judiciary.
- Development and Procedural History
- Referral and Investigation
- In a Resolution dated 28 September 2005, the Second Division of the Supreme Court referred the administrative case to Court of Appeals Justice Josefina G. Salonga.
- Justice Salonga was tasked to investigate, prepare a report, and render a recommendation within ninety (90) days.
- Hearing and Submission of Evidence
- The investigation hearing was scheduled on 13 December 2005.
- Both the complainant and the respondents (Judge Fe and Atty. Corpuz) presented documentary evidence.
- They filed their respective Memoranda on different dates: petitioner on 13 December 2005, respondent Judge on 18 January 2006, and respondent lawyer on 20 January 2006.
- Factual Background of the Underlying Civil Cases
- The narrative includes a property dispute involving a mortgage foreclosure, a public auction, and subsequent issues of succession and contractual nullification.
- Details on the mortgage:
- In October 1992, Salud Andrada Marquez mortgaged six parcels of land.
- Due to non-payment, the Rural Bank foreclosed the properties, with one parcel being particularly noted (22,599 sq. meters at Calumbaya, Bauang, La Union).
- A public auction in August 1993 resulted in the petitioner acquiring the property.
- Transition in legal representation and court assignments:
- Initially, respondent Judge Fe, when still a practicing lawyer, drafted a complaint for Civil Case No. 1081-BG.
- Later events led to the reassignment of Civil Case No. 1518-BG to the same judge, who upon noticing a potential conflict of interest (given his former client status with Roque), issued an Order on 23 January 2004 to inhibit himself and transferred the case records accordingly.
- Subsequent Developments
- The filings and transfers related to the civil cases continued in the relevant RTC branches.
- Despite these rectifications, the complainant pursued the administrative complaint, alleging misconduct on the part of the respondents.
Issues:
- Whether there was sufficient evidence to support the complainant’s allegations that respondent Judge Fe allowed improper access to case records of Civil Case No. 1081-BG to benefit respondent lawyer.
- Did the respondent Judge, by his actions, facilitate any unethical advantage for the respondent lawyer?
- Was there a breach of protocol in allowing the copying or rewriting of previously filed complaint documents?
- Whether the alleged copying of substantial portions of the complaint from Civil Case No. 1081-BG into Civil Case No. 1518-BG constitutes malice or wrongful intent amounting to serious misconduct.
- To what extent do similarities between the two complaints reflect unethical behavior or simply the reuse of essential allegations necessary for the case?
- Does the evidence reveal any deliberate misconduct by the respondents in misappropriating legal documents?
- Whether the administrative complaint was filed in good faith or was merely a vehicle to harass and cast doubt on the integrity of the respondents and the Judiciary.
- Is the complainant’s allegation based on mere speculation and conjecture rather than supported evidence?
- Should the burden of proof in administrative proceedings, which rests on the complainant, be considered unmet in this instance?
- Whether the conduct of filing a frivolous and unfounded administrative complaint warrants the sanction imposed, including possible contempt and penalties.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)