G.R. No. 189980 - People vs. Alcuizar

On September 6, 2005, Erlinda Marquez, in her personal capacity and as attorney-in-fact of Bienvenido O. Marquez IV, Anna Corina Gisela O. Marquez, and Paz Louella Erica Beatriz O. Marquez, filed a complaint for annulment of foreclosure proceedings, certificate of sale, and transfer certificate of title against United Coconut Planters Life Assurance Corporation (COCOLIFE), Register of Deeds of Quezon City, and Ex-Officio Sheriff of Quezon City (Civil Case No. Q-05-5629).
The Regional Trial Court (RTC), Quezon City, Branch 77, dismissed the complaint on January 28, 2008.
The Court of Appeals affirmed the dismissal on November 6, 2009.
The Supreme Court denied the petition for review via Resolution dated July 26, 2010, which became final and executory on September 22, 2010.

On July 26, 2013, the heirs of Bienvenido O. Marquez, Jr., through their lawyer Atty. Bonifacio A. Alentajan, filed another complaint for reconveyance and annulment of title with application for preliminary injunction and temporary restraining order against COCOLIFE and Register of Deeds (Civil Case No. R-QZN-13-02119-CV).
This complaint was dismissed by the RTC, Branch 90 of Quezon City, on November 12, 2013.
Erlinda, assisted by Atty. Alentajan, filed a criminal complaint against COCOLIFE officers for violations of R.A. No. 7653 and R.A. No. 3765. The complaint was dismissed by the Office of the City Prosecutor (OCP) of Makati City on July 2, 2014 for lack of merit; a motion for reconsideration was denied on September 16, 2014.
Another criminal complaint for robbery under Article 302 of the RPC was filed but dismissed by the OCP of Quezon City on January 17, 2014 due to insufficiency of evidence.
A Petition for Contempt against COCOLIFE officers was also filed but dismissed by RTC, Branch 92, Quezon City on March 24, 2014.

On October 2, 2014, COCOLIFE, through Guillermo Villanueva, filed a Complaint for Disbarment against Atty. Alentajan before the Integrated Bar of the Philippines (IBP).
The complaint alleged that Atty. Alentajan committed forum shopping by filing multiple suits regarding the same property without proper certification or disclosure of previous cases.
Atty. Alentajan denied authority of Villanueva to represent COCOLIFE in the disbarment case, questioned the relevance of the board resolution dated April 26, 2011, and denied knowledge of the complaint’s filing date in 2014.

The IBP Investigating Commissioner found Atty. Alentajan guilty of violating Canon 10, Canon 12, and Rule 7, Section 5 of the Rules of Court, recommending a three-month suspension with warning on June 30, 2015.
The IBP Board of Governors adopted the recommendation and suspended Atty. Alentajan for three months on June 17, 2017.
The IBP forwarded the case to the Supreme Court for final adjudication pursuant to the Rules of Court.

Whether Atty. Bonifacio A. Alentajan committed forum shopping and other acts charged in the complaint.
Whether COCOLIFE, through Guillermo Villanueva, had the authority to file the disbarment complaint against Atty. Alentajan.