Title
Velasco vs. Doroin
Case
A.C. No. 5033
Decision Date
Jul 28, 2008
A disbarment case involving forgery, falsification, and deceit by Atty. Doroin and Atty. Centeno, leading to indefinite suspension and disbarment, respectively.
A

Case Summary (G.R. No. 173844)

Procedural History and Defaults

The complainant filed a disbarment complaint alleging forgery and falsification by the respondent lawyers. The Supreme Court’s Second Division required respondents to comment within ten days but respondents failed to file the comment despite an extension. The Court issued show-cause orders and imposed fines (including a fine against Atty. Charlie Doroin that was later paid), and directed the complainant to provide correct addresses for certain counsel. The Integrated Bar of the Philippines (IBP) was later referred the case for investigation and report. Respondents repeatedly failed to file comments or appear at IBP proceedings; notices sent to them were returned with notations indicating they had moved, and the IBP declared the respondents in default. The Commission on Bar Discipline submitted a report and recommendation, and the IBP Board of Governors considered and modified the recommended penalty before transmitting the matter to the Court.

Core Allegations and Factual Findings Presented

The complainant alleged that she had been appointed administratrix in a special proceedings case involving the estate of the late Eduardo Doroin, and that respondents, acting as collaborating counsel for an oppositor, deceived the complainant into signing an extrajudicial settlement and partition that disadvantaged her and omitted the legal spouse’s share. The complaint alleges that respondent Atty. Doroin procured or caused the forging of the deceased’s signature on a Deed of Absolute Sale conveying a lot in Kingspoint Subdivision to a third party and that respondent Atty. Centeno, a notary public, notarized a Deed of Absolute Sale by making it appear that the deceased had personally appeared before him after the date of death. The record also notes that a criminal case for falsification of public document was filed against Atty. Centeno (Criminal Case No. 104869), that he pleaded not guilty at arraignment, and that he later failed to appear and jumped bail.

IBP Investigation, Findings and Recommendation

The IBP Commission on Bar Discipline, after mandatory conference/hearing notices and follow-up hearings at which respondents did not appear and were declared in default, found that respondents had violated Rule 1.01, Canon 1 of the Code of Professional Responsibility by engaging in dishonest conduct that caused “extreme and great damage” to the complainant. The Commission recommended disbarment. The IBP Board of Governors adopted the Commission’s findings but modified the recommended penalty to indefinite suspension (instead of disbarment) for the respondents and transmitted its resolution and the Commission’s report to the Court.

Legal Standards and Burden of Proof Applied

The Court applied Rule 1.01, Canon 1 of the Code of Professional Responsibility, which provides that a lawyer shall not engage in unlawful, dishonest, immoral or deceitful conduct. The Court reaffirmed the high ethical standards required of lawyers, citing the lawyer’s oath and precedent (e.g., Marcelo v. Javier) that require attorneys to uphold the integrity and dignity of the profession and that disciplinary action is proper where conduct renders an attorney unfit to practice. The record reiterates the established rule that the burden of proof in disciplinary proceedings rests on the complainant and that guilt must ordinarily be established by clear, convincing and satisfactory proof; however, the Court also recognized that a respondent’s failure to answer a complaint and to appear at investigation hearings leaves the complainant’s allegations uncontroverted and may be treated as evidence of flouting lawful orders and a breach of the lawyer’s oath (as explained in Ngayan v. Tugade and cited in the record).

Court’s Analysis and Reasoning

The Court accepted the factual allegations in the complaint as uncontroverted given respondents’ default and non-appearance before the IBP and failure to file comments despite due notice and multiple opportunities. The Court observed that the alleged conduct—causing or participating in the forgery of a deed of sale and the notarization of a document that falsely purported a personal appearance by a deceased person—constitutes dishonest and deceitful conduct in violation of Rule 1.01. The Court further framed the misconduct in the context of succession law (Civil Code, Art. 887) and the proper procedure for extrajudicial settlement (Rules of Court, Rule 74), emphasizing that compulsory heirs, including a surviving spouse, cannot be deprived of their legitime by an extrajudicial settlement in which the spouse is not a party. The Court considered the gravity of the misconduct and the additional aggravating circumstance in Atty. Centeno’s case: the commission of a criminal offense (falsification of a public document) and subsequent absconding after posting bail, which the record identifies as a distinct and serious factor.

Disposition and Penalties Imposed

The Court agreed with the IBP’s findings of professional misconduct but differentiated the penalties for the two respondents based on the circumstances detailed in the record. Atty. Charlie Doroin was suspended indefinitely from the practice of

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