A.C. No. 10564 - Valin vs. Ruiz

Complainants Manuel L. Valin and Honorio L. Valin are surviving children of Pedro F. Valin (Pedro) and Cecilia Lagadon (Cecilia).
Pedro was the original registered owner of an 833-square-meter parcel of land in San Andres, Sanchez Mira, Cagayan, covered by Original Certificate of Title (OCT) No. P-3275(S).
Pedro died on December 7, 1992, in Oahu, Honolulu, Hawaii.

Several years after Pedro’s death, Honorio discovered the subject land was transferred to respondent Atty. Rolando T. Ruiz, Pedro’s godson, resulting in the cancellation of the original title and issuance of Transfer Certificate of Title (TCT) No. T-11655(s) in the respondent’s name.
The transfer was effectuated through a Deed of Absolute Sale dated July 15, 1996, executed in Tuguegarao City and purportedly signed by Pedro and Cecilia with a sale price of P10,000.00.
Complainants alleged the deed was falsified and the signatures forged since Pedro was already dead and Cecilia was in Hawaii at the time.
Pedro’s Community Tax Certificate (CTC) No. 2259388, used in the deed, was also forged since it was purportedly issued on January 2, 1996, after Pedro’s death.
Complainants pointed to respondent as the author of the falsifications, as he benefited from the transfer.

Respondent claimed Rogelio L. Valin (Rogelio), one of Pedro’s children, sold the land to him in 1989 representing Pedro.
Respondent bought the land at P26,000.00 to help Rogelio defray surgical costs of Rogelio’s son.
Rogelio failed to locate written authority from his parents to sell but claimed he had it.
Respondent acknowledged difficulties in transferring title without a Special Power of Attorney (SPA) since Pedro was abroad, and Rogelio purportedly undertook title transfer.
Respondent denied knowledge of the 1996 deed, the falsification of signatures, or issuance of Pedro’s CTC and claimed his house helper, Judelyn Baligad, signed release of title on his behalf in 1996 as he was busy.

IBP-CBD found respondent guilty of misconduct, presuming him author of the false deed due to the benefit he gained and inability to prove otherwise, recommending suspension for 2 years.
IBP Board of Governors approved the recommendation; respondent’s motion for reconsideration was denied.
Respondent filed a petition for review before the Supreme Court, denying misconduct and alleging lack of factual and legal basis.
Respondent attached a purported written authority dated September 13, 1989, allegedly from Pedro allowing Rogelio to sell the property, presented on appeal but not before IBP.
Complainants failed to file comment to respondent’s petition.
Case submitted for resolution on March 1, 2016.

Whether respondent Atty. Rolando T. Ruiz violated the Lawyer’s Oath, Rule 1.01, and Rule 10.01 of the Code of Professional Responsibility by participating in or benefiting from the falsified Deed of Absolute Sale executed after Pedro’s death.
Whether respondent’s claim of acting in good faith and ignorance of the falsification is credible to absolve him from liability.
Whether a lawyer’s misconduct in a private transaction not related to his profession may be a ground for disciplinary action and suspension from the practice of law.
Proper penalty to be imposed on respondent for the misconduct.