G.R. No. 224015 - Juego-Sakai vs. Republic

On February 2, 2004, David W. Williams, an American citizen, filed a disbarment complaint against Atty. Rudy T. Enriquez.
Williams alleged Enriquez engaged in unlawful, dishonest, immoral, and deceitful conduct unbecoming of a lawyer by filing multiple malicious and baseless suits involving a property in Negros Oriental covered by Transfer Certificate of Title (TCT) No. T-19723.
The Court directed Enriquez to file a comment, who instead filed a Motion to Dismiss, claiming the charges were reckless and malicious.
The case was referred to the Integrated Bar of the Philippines (IBP) for investigation and recommendation.

The property involved was Lot 2920 in San Miguel, Bacong, Negros Oriental, originally owned by Aurea Briones with title transferred to Josephine Verar through a valid deed of sale in 1977.
Josephine died leaving the property to her son, Orlando Verar Rian, Jr.
Orlando sold portions of the lot and had the title reconstituted, subdividing the lot into four parts approved by the DENR.
Aurea's relatives engaged Enriquez, who drafted a Declaration of Heirship and Partition dividing the lot into six parts, naming himself one of the heirs and allotting himself one-sixth of the lot as contingent fees.
This document was prepared with numerous falsehoods including claims about Aurea's date of death and ownership status.

Williams’ wife agreed to buy part of the subdivided lot from Orlando.
Enriquez and Aurea's relatives took actions to assert ownership over the disputed area, constructing fences and filing multiple cases (malicious mischief, forcible entry) against Williams.
Enriquez made false representations about the ownership to intimidate and harass Williams and his wife.
Williams was eventually acquitted in the malicious mischief case.
Enriquez's pleadings and accusations included falsified declarations and the misrepresentation of heirs’ surnames.

The IBP investigative commissioner found Enriquez made false statements and suppressed material facts in the Declaration of Heirship and Partition.
The commissioner recommended a one-year suspension for Enriquez.
The IBP Board of Governors (BOG) approved the findings but increased the penalty to a two-year suspension.

Enriquez filed motions for reconsideration maintaining the legitimacy of his claims, arguing contingent fees were allowed and that complainant's allegations were malicious.
Enriquez also filed a petition for contempt against Williams, alleging breach of confidentiality by sharing IBP's report with other offices.
Williams denied the breach and claimed the sharing was necessary due to related property cases.

The Supreme Court treated Enriquez's second motion for reconsideration as a petition for review.
Williams filed comments expressing frustration with the Philippine legal system.
Enriquez moved for dismissal due to Williams’s alleged failure to file adequate comments.

Whether complainant Williams breached the confidentiality rule regarding administrative proceedings against lawyers by sharing the IBP's report?

Whether the present administrative disbarment complaint can be used as a substitute to invalidate the Declaration of Heirship and Partition involving the subject property?