Facts:

• Sylvia R. Rivera filed a disbarment complaint against Atty. Bayani P. Dalangin.
• Sylvia, the surviving spouse of Teofilo Rivera, and Nicasio Rivera, Teofilo's son from another woman, initially filed a civil case for annulment of documents, cancellation of title, and damages against Felipe Pecache and the Register of Deeds of Nueva Ecija.
• The Regional Trial Court (RTC) dismissed the case for lack of merit.
• Sylvia and Nicasio appealed to the Court of Appeals (CA), which affirmed the RTC's decision.
• They enlisted Atty. Dalangin, who prepared a motion for reconsideration that was granted by the CA, resulting in a favorable ruling.
• Atty. Dalangin filed a motion for execution of judgment and a motion to clarify the writ of execution.
• Sylvia later discovered that Nicasio and his wife, Emily de Luna, executed an Affidavit of Self-Adjudication with Sale, selling Teofilo's property to Spouses James Martin and Mary Ann Wy for P100,000.00.
• Sylvia filed a complaint for annulment of the affidavit and cancellation of the new title issued to the Spouses Wy.
• The Spouses Wy presented a Deed of Absolute Sale dated May 28, 2009, notarized by Atty. Dalangin, with a consideration of P4,000,000.00.
• Sylvia claimed the deed was antedated to prevent her consignment and that Atty. Dalangin was aware of her interest in the property.
• Sylvia filed a disbarment complaint against Atty. Dalangin for deceit and dishonesty, supported by evidence of his failure to submit notarial reports.
• Atty. Dalangin denied representing Sylvia, claimed he was hired by Nicasio, and denied antedating the deed of sale.
• The Integrated Bar of the Philippines (IBP) found Atty. Dalangin guilty of violating the Code of Professional Responsibility and the Rules on Notarial Practice, recommending his suspension from law practice for two years, revocation of his notarial commission, and disqualification from being a notary public for two years.
• The IBP Board of Governors later modified the penalty, removing the suspension.

Issue:

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Ruling:

1. Yes, Atty. Bayani P. Dalangin engaged in deceit and dishonesty by misrepresenting his representation of Sylvia Rivera.
2. Yes, Atty. Dalangin violated the rules on notarial practice by notarizing a deed of absolute sale despite being aware of conflicting interests.
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Ratio:

• The Supreme Court adopted the IBP's findings with modifications to the penalty.
• The Court emphasized that the Code of Professional Responsibility mandates every lawyer to obey the laws and legal processes, upholding the integrity and dignity of the legal profession.
• Atty. Dalangin exhibited dishonesty by denying his representation of Sylvia Rivera, despite clear evidence from the case records and motions he filed on behalf of both Sylvia and Nicasio.
• The Court found that Atty. Dalangin should have been aware of Sylvia's interest in the property and should have refused to notarize the deed of absolute sale, knowing it excluded a legal heir.
• This act violated Canons 1 and 7 of the Code of ...continue reading