A.C. No. 5439 - Samala vs. Valencia

Clarita J. Samala, the complainant, filed a complaint against Atty. Luciano D. Valencia for disbarment.
The complaint was based on four main grounds:

Serving as counsel for contending parties in litigation.
Knowingly misleading the court by submitting false documentary evidence.
Initiating numerous cases in exchange for nonpayment of rental fees, reflecting a conflict between professional duty and personal gain.
Having a reputation for immorality by siring illegitimate children, which detracts from the moral standards expected of legal professionals.

After respondent’s comment, the case was referred to the Integrated Bar of the Philippines (IBP) for investigation.
Commissioner Demaree Jesus B. Raval conducted the investigation, including a series of hearings and the submission of memoranda by both parties.
Commissioner Wilfredo E.J.E. Reyes prepared a Report and Recommendation finding the respondent guilty of violating Canons 15 and 21 of the Code of Professional Responsibility, initially recommending a suspension of six months.
The IBP Board of Governors adopted the report and increased the penalty from six months to one year.

Records revealed that respondent acted as counsel for opposing parties in several cases:

In Civil Case No. 95-105-MK at the RTC, Branch 272, Marikina City, he represented defendant Valdez while also filing documents for tenants Lagmay, Valencia, Bustamante, and Bayuga.
In Civil Case No. 98-6804 at the Metropolitan Trial Court (MTC), Branch 75, Marikina City, he represented Valdez against Bustamante, a tenant, even when the same case led to a subsequent appeal (SCA Case No. 99-341-MK).
In Civil Case No. 2000-657-MK at the RTC, Branch 273, showing his continuing involvement in related matters on behalf of contending interests, particularly when defending both Valdez and Alba.

Respondent’s admissions during the hearings further detailed his dual representations and his attempt to differentiate between former and current client relationships, which was found insufficient under the required ethical standards.

In Civil Case No. 00-7137 for ejectment filed before MTC, Branch 75, respondent submitted TCT No. 273020 as evidence of Valdez’s ownership of the property.
It was found that a new title (TCT No. 275500) had already been issued in the name of Alba, rendering the submitted title false.
Despite his aversion that he learned of the title discrepancy later, evidences showed that both Civil Case No. 00-7137 and the related Civil Case No. 2000-657-MK were filed on the same day, thus negating his claim of ignorance.

Respondent filed several cases purportedly to safeguard a retainer arrangement with his client Valdez, who had been allowed to occupy and use a property in lieu of rental fees.
The cases in question include:

Civil Case No. 2000-657-MK (filed at the RTC, Branch 272).
Civil Case No. 00-7137 (filed at the MTC, Branch 75).
Criminal cases under I.S. Nos. 00-4439 and 01-036162 in connection with estafa and grave coercion issues.

The filing of these cases, though argued as a measure to protect the client’s rights, was scrutinized to determine if such filings abused judicial processes.

Respondent admitted to having sired three illegitimate children with Teresita Lagmay while still married to his first wife.
He also acknowledged having eight children with his first wife before her death in 1997, and subsequently married Lagmay in 1998.
During the hearings, his justification minimized a genuine marital relation with Lagmay and displayed no remorse, thereby failing to uphold the moral and ethical standards demanded of lawyers.

Whether Atty. Luciano D. Valencia’s simultaneous representation of conflicting parties in various civil cases constituted a breach of duty under the Code of Professional Responsibility.
Whether his submission of false documentary evidence with the use of an already cancelled Transfer Certificate of Title (TCT) intentionally misled the court.
Whether initiating multiple cases linked to the rental fee arrangement was an abuse of judicial process or merely a valid defense of his client’s interests.
Whether his personal conduct, namely the siring of illegitimate children and subsequent justification of his behavior, amounted to immoral conduct that discredits his professional standing.