Case Summary (A.C. No. 11774)
Factual Antecedents
Ready Form participated in a public bidding by the NPO on October 17, 2008, and subsequently faced suspension due to alleged false financial statements submitted for the years 2006 and 2007. Eastland Printink Corporation filed a Petition for Blacklisting against Ready Form, claiming misrepresentation and other violations, which Atty. Castillon, as Eastland's counsel, signed. The NPO issued a resolution suspending and blacklisting Ready Form for five years, citing falsified documents.
Allegations and Legal Framework
On April 4, 2014, Ready Form lodged a complaint alleging Atty. Castillon’s unlawful use of its ITR violated several provisions, including Sections 4 and 278 of Republic Act No. 8424 (National Internal Revenue Code) and Section 30.1 of the Implementing Rules and Regulations of Republic Act No. 9184 (Government Procurement Reform Act). The allegations suggest that Atty. Castillon misused confidential financial data acquired from the Bureau of Internal Revenue.
Respondent’s Defense
Atty. Castillon denied the allegations, asserting that only Ready Form's publicly available audited financial statements were attached to the Petition for Blacklisting. He refuted claims that he acquired or attached any ITR from Ready Form, maintaining that his documentation complied with legal standards.
Findings of Commissioner
Commissioner Maria Editha A. Go-BiAas, after conducting proceedings, recommended dismissing the case against Atty. Castillon, stating there was no evidentiary support for the claims that he procured or misused the ITR. The IBP Board of Governors adopted these findings, affirming the recommendation for dismissal.
Court’s Ruling
Upon reviewing the matter, the Court aligned with the findings of Commissioner Go-BiAas. The core issue was whether Atty. Castillon violated the law by allegedly attaching Ready Form’s ITR to the Petition. The Court clarified that Atty. Castillon attached only the audited financial statement,
...continue readingCase Syllabus (A.C. No. 11774)
Overview of the Case
- The case involves an administrative complaint filed by Ready Form, Inc. against Atty. Egmedio J. Castillon, Jr.
- The complaint was lodged with the Commission on Bar Discipline of the Integrated Bar of the Philippines (CBD-IBP).
- Allegations against Atty. Castillon included violations of Rules 1.01, 1.02, and 1.03 of Canon 1 of the Code of Professional Responsibility.
- The primary accusation centered on Atty. Castillon’s alleged use of Ready Form's Income Tax Return (ITR) in a Petition for Suspension and Blacklisting against Ready Form.
Factual Antecedents
- Ready Form participated in a public bidding by the National Printing Office (NPO) on October 17, 2008.
- Following the bidding, the NPO-Bids and Awards Committee (NPO-BAC) required resubmission of eligibility documents, including past ITRs.
- The NPO-BAC suspended Ready Form for one year starting December 22, 2008, due to alleged misrepresentation through false ITRs and financial statements for 2007.
- Eastland Printink Corporation filed a Petition for Blacklisting against Ready Form, claiming misrepresentation in ITRs for both 2006 and 2007 and other violations.
- Atty. Castillon represented Eastland and signed the Petition for Blacklisting, which led to a request for position papers from both parties.
NPO's Findings and Resolution
- On December 1, 2009, the NPO found Ready Form guilty of submitting falsified documents, leading to a five-year