Case Summary (A.C. No. 4517)
Nature of the Complaint
The complaint for disbarment against Attys. Fabros and Paas was premised on allegations of engaging in "unlawful, dishonest, immoral or deceitful conduct" regarding their roles as chairman and vice-chairman of the provincial board of canvassers during the 1995 senatorial elections in Isabela. The specific charges outline that the respondents falsified election results through a fraudulent alteration of the Statement of Votes per Municipality, thereby contravening their legal and professional responsibilities.
Duties of the Respondents
As officials of the PBC-Isabela, the respondents were tasked with canvassing the election results from various municipalities and submitting a Provincial Certificate of Canvass to the Commission on Elections (COMELEC). This involved certifying under oath the accuracy and integrity of the canvassed votes, a duty they failed to uphold as evidenced by the inconsistencies in the documentation submitted.
Evidence of Misconduct
The allegations were substantiated by a comparison of the fabricated Statement of Votes with the municipal/city certificates, revealing evidence of vote padding by significant margins for specific candidates. This blatant misconduct signified a deliberate act of falsification rather than mere error, highlighting the respondents' awareness and willful participation in a flawed electoral process.
Respondents' Defense
In their defense, the respondents denied any wrongdoing. Atty. Fabros claimed there was no consent to manipulate the results, asserting the canvassing was conducted transparently. Atty. Paas supported this by attributing discrepancies to human error and fatigue rather than malicious intent. However, both acknowledged signing documents that contained false figures, which undermined their claims of innocence.
Proceedings and Findings
The Integrated Bar of the Philippines (IBP) conducted an investigation into the complaint, finding the respondents guilty of breaching Rule 1.01 of the Code of Professional Responsibility by engaging in dishonest conduct as licensed attorneys. The IBP's board of governors recommended a penalty of a fine of P10,000 for each respondent, underscoring the need for accountability in their professional duties.
Final Ruling and Implications
The Court upheld the IBP's findings, emphasizing that as public officers, the respondents had an obligation to maintain the integrity o
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Case Overview
- A complaint for disbarment was lodged against Attys. Vitaliano C. Fabros and Pacifico S. Paas by Senator Aquilino Q. Pimentel Jr.
- The complaint was based on allegations of "unlawful, dishonest, immoral or deceitful conduct" tied to their roles as chairman and vice-chairman of the Provincial Board of Canvassers for the Province of Isabela during the 1995 elections.
- The central issues involved the preparation and certification of the Provincial Certificate of Canvass and the Statement of Votes per Municipality, which were alleged to contain fraudulent alterations.
Responsibilities of the Provincial Board of Canvassers
- The primary function of the PBC-Isabela was to canvass election results from various municipalities and cities within the province.
- They were required to submit the Provincial Certificate of Canvass to the Commission on Elections (COMELEC) along with a supporting Statement of Votes.
- Respondents were mandated to certify under oath the accuracy and truthfulness of the canvassed results.
Allegations of Misconduct
- It was alleged that the Statement of Votes per Municipality, certified by the respondents, c