Case Summary (A.C. No. 7181)
Background of the Complaint
The case involves a complaint against Atty. Leonido C. Delante for gross violations of the Code of Professional Responsibility, initiated by the heirs of Angalan Samal and Sanaan Samal. The complainants, who are illiterate members of the Samal Tribe, owned a 9.102-hectare parcel of land covered by Original Certificate of Title No. P-11499. The complainants allege that they were manipulated into signing a deed of absolute sale instead of a mortgage when they borrowed P15,000 from the Spouses Eustaquio, resulting in the loss of their property.
Engagement of Legal Services
The complainants hired respondent Atty. Delante to assist in recovering their property after realizing they were misled into an absolute sale. Respondent acknowledged receipt of P1,200 as full payment for his professional services regarding the recovery of the title. However, subsequent actions indicated respondent falsely represented their situation and acted against their interests.
Legal Proceedings Initiated by the Respondent
In 1976, respondent filed a complaint to recover the property, affirming that the complainants had the right to repurchase the land according to Public Land Law. An amicable settlement was reached with the Spouses Eustaquio, wherein the complainants were to pay a total of P30,000 to repurchase the property, which respondent advanced. Despite his representation of the complainants, he subsequently claimed ownership over the property.
Various Transactions and Conflicts
After the complainants attempted to repay the advance and reclaim their property, they discovered that respondent had transferred the title to his name, designating himself as the owner. This act constituted a breach of trust, especially given the complainants’ documentation showing they had repurchased the land.
Response to Complaints and Allegations
In his defense, respondent claimed that he was not the complainants’ lawyer, asserting that they sought his advice merely on borrowing money. He alleged that a client from New York bought the property under his name while waiting for his client to return. However, the Court found these claims inconsistent and unsupported by evidence.
Findings from the Integrated Bar of the Philippines (IBP)
The investigation carried out by the IBP concluded respondent had committed gross misconduct by violating the confidence placed in him by the complainants. The IBP’s report indicated that respondent's rationale for purchasing the property on behalf of a client was implausible and did not stand up to the substantial evidence presented by the complainants.
Court’s Assessment and Conclusion
The Court held that respondent’s actions amounted to serious violations of Canons 16 and 17 of the Code of Professional Responsibility,
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Case Overview
- Complainants: Maria, Nena, Dionicio, Magdalena, Francisca, Inis, Rosalino, and Josefina Angalan, heirs of Angalan Samal and Sanaan Samal.
- Respondent: Atty. Leonido C. Delante.
- Nature of Complaint: Gross violation of the Code of Professional Responsibility by the respondent.
- Property in Dispute: 9.102-hectare parcel of land in Barrio San Jose, Kaputian, Island Garden City of Samal, Davao del Norte, covered by Original Certificate of Title (OCT) No. P-11499.
Background Facts
- The Angalan family, comprising complainants and their deceased patriarch Angalan, owned a significant piece of land.
- On April 15, 1971, the family borrowed P15,000 from the Spouses Eustaquio, mortgaging 8.102 hectares of their property as collateral.
- Complainants, who are illiterate and members of the Samal Tribe, were misled into signing a deed of absolute sale instead of a mortgage.
Events Following the Loan
- When the complainants attempted to repay the loan and retrieve their title, they discovered that the document they signed was not a mortgage but a sale, leading to the cancellation of OCT No. P-11499 and the issuance of Transfer Certificate of Title (TCT) No. T-9926 in the name of Navarro Eustaquio.
- The complainants engaged respondent Atty. Delante to assist them in recovering their property.
Engagement of Legal Services
- Respondent acknowledged receipt of P1,200 as full payment for his professional fees related to the recovery of OCT No. P-11499.
- Responde