A.C. No. 9257 - Rico vs. Salutan

Complainant Edgar M. Rico filed a letter complaint against respondent Atty. Reynaldo G. Salutan, alleging that the lawyer misled the court and committed contempt in connection with a property dispute.
The complaint was directed to Judge Antonio P. Laolao, Sr., Presiding Judge of Municipal Trial Court, Branch 6, Davao City.

Rico’s relatives were plaintiffs in a civil case for Forcible Entry before the Municipal Trial Court in Cities (MTCC), Branch 4, Davao City, where the defendants were ordered to restore possession of certain properties to the plaintiffs, remove unauthorized structures, and compensate for occupation.
In a separate proceeding, defendant Milagros Villa Abrille, represented by Atty. Salutan, filed a case for Unlawful Detainer against Rico concerning the same property.

On November 6, 2001, the MTCC ordered Rico to vacate the premises following Villa Abrille’s separate filing.
The Regional Trial Court (RTC) affirmed the MTCC ruling and issued a Writ of Execution.
On July 9, 2004, the court’s sheriff executed a Return of Service, noting that the writ could not be properly served because the property designated in the writ differed from the lot Rico occupied.

Villa Abrille, through her counsel Atty. Salutan, filed a motion for an Alias Writ of Execution.
On May 15, 2007, the sheriff executed a Return of Service again because the alias writ could not be enforced for the same discrepancy in property description.
On April 4, 2008, a subsequent motion for another Alias Writ of Execution was filed but denied by the MTCC.
Villa Abrille then sought a Writ of Mandamus to compel the issuance of a new Writ of Execution and its implementation by the sheriff, yet the case was dismissed.
For the fourth time, Villa Abrille filed another motion which was finally granted by the MTCC.

On June 10, 2010, the court sheriff issued a Final Notice to Vacate to Rico.
On June 15, 2010, the same sheriff led the demolition of the house and other improvements on the property.

In response to the demolition and the subsequent issues raised, Rico filed an administrative complaint against Atty. Salutan, alleging that he misled the court and committed misconduct.
Atty. Salutan denied the allegations, asserting that his conduct was that of a zealous lawyer advocating for his client within the bounds of the law and legal ethics.

On January 2, 2013, the Investigating Commissioner of the Commission on Bar Discipline of the Integrated Bar of the Philippines (IBP) recommended the dismissal of the complaint, concluding that the complaint was without merit.
On March 21, 2013, the IBP Board of Governors adopted Resolution No. XX-2013-357, which dismissed the case based on the report and recommendation.
Rico then moved for reconsideration, but on March 23, 2014, the IBP Board of Governors passed Resolution No. XXI-2014-183, denying the motion for reconsideration and affirming the previous resolution.

Whether Atty. Reynaldo G. Salutan’s actions in representing Villa Abrille demonstrated misleading conduct before the court.

Determining if his legal advocacy crossed the line into misrepresentation or undue influence in court proceedings.

Whether the administrative complaint against Atty. Salutan was supported by sufficient and substantial evidence.

Assessing the burden of proof required in administrative disciplinary proceedings.
Evaluating if mere allegations, without substantial proof, are adequate to invoke disciplinary measures against a lawyer.

Whether the standard and evidentiary threshold applicable in administrative proceedings were satisfied by the complainant.

Examining if the complainant met the requirement of demonstrating substantial evidence rather than relying on mere suspicion or speculation.