The Supreme Court, in this administrative case, addressed the ethical responsibilities of lawyers and the consequences of violating the Code of Professional Responsibility. The Court suspended Atty. Domingo C. Laeno for five years due to his involvement in executing multiple deeds of sale with undervalued considerations for a single property, and for presenting one of these false documents as evidence in court. This decision underscores the judiciary’s commitment to maintaining the integrity of the legal profession by penalizing acts of dishonesty and misrepresentation, thereby safeguarding public trust in the legal system.

Double Deeds and Deceptive Defense: When an Attorney’s Actions Undermine Legal Ethics

This case began with a property sale dispute involving Atty. Domingo C. Laeno and Marcelina Agustin, mother of Atty. Ferdinand S. Agustin. The conflict arose after Atty. Laeno failed to make rental payments on a property he sold to Marcelina, leading to an ejectment case. During the proceedings, it was discovered that Atty. Laeno had executed two separate Deeds of Absolute Sale for the same property, both notarized by Atty. Reginaldo D. Bergado, each reflecting different and undervalued considerations. Atty. Laeno then presented one of these deeds as evidence, further complicating the matter. This led to an administrative complaint against Attys. Laeno, Robiso, and Bergado for violating the Code of Professional Responsibility.

The Integrated Bar of the Philippines (IBP) investigated the matter and found Atty. Laeno guilty of misconduct for executing two deeds of sale for one property, attempting to avoid eviction through multiple lawsuits, and knowingly presenting a false deed as evidence. Atty. Bergado was found guilty of violating notarial law by notarizing both deeds for the same property. The IBP recommended suspending Atty. Laeno from the practice of law for two years and revoking Atty. Bergado’s notarial commission. The Supreme Court agreed with the IBP’s findings regarding Atty. Laeno but increased the suspension period to five years, emphasizing the severity of his transgressions. As for Atty. Bergado, the case was closed due to his death, which was overlooked during the IBP investigation.

The Supreme Court’s decision hinged on the violation of several canons of the Code of Professional Responsibility. Canon 1 mandates that lawyers must uphold the law and promote respect for legal processes. Atty. Laeno’s actions, specifically the creation and use of the false deeds, were a clear violation of this canon. Canon 7 requires lawyers to maintain the integrity and dignity of the legal profession. By engaging in deceptive practices, Atty. Laeno undermined public trust in the legal system and brought disrepute to the profession. Furthermore, Canon 10 emphasizes the lawyer’s duty to be candid, fair, and act in good faith towards the court. Presenting a bogus deed of sale as evidence was a direct breach of this duty.

Atty. Laeno’s attempts to avoid eviction through multiple lawsuits also violated Canon 12, which directs lawyers to assist in the speedy and efficient administration of justice. Filing frivolous or dilatory suits to delay legal proceedings is a disservice to the court and the public. The Court emphasized the importance of lawyers abiding by court judgments, even those unfavorable to them. The Court, quoting Lazareto v. Atty. Acorda, reiterated that “the ethics of the legal profession rightly enjoins every lawyer to act with the highest standards of truthfulness, fair play, and nobility in the course of his practice of law.”

The case underscores that actions speak louder than words, and the legal profession demands a commitment to ethical conduct that goes beyond mere compliance. It is a reminder that lawyers are officers of the court and must uphold the highest standards of honesty and integrity.
The consequences of failing to do so can be severe, including suspension from the practice of law. The Court’s decision serves as a deterrent to other lawyers who may be tempted to engage in similar misconduct. By imposing a stricter penalty than recommended by the IBP, the Court sent a clear message that such behavior will not be tolerated.

FAQs

What was the key issue in this case?	The key issue was whether Atty. Laeno and Atty. Bergado violated the Code of Professional Responsibility and the Notarial Law through their actions related to the execution and presentation of false deeds of sale.
What specific violations did Atty. Laeno commit?	Atty. Laeno violated Canons 1, 7, 10, and 12 of the Code of Professional Responsibility by executing two deeds of sale for one property, indicating an undervalued consideration, presenting a false deed as evidence, and filing multiple suits to avoid eviction.
What was the penalty imposed on Atty. Laeno?	The Supreme Court suspended Atty. Laeno from the practice of law for five years.
What was Atty. Bergado’s involvement in the case?	Atty. Bergado notarized the two Deeds of Absolute Sale, both covering the same property but with different and undervalued considerations, which was a violation of notarial law and Canon 1 of the Code of Professional Responsibility.
Why was the case against Atty. Bergado not pursued?	The case against Atty. Bergado was not pursued because he had already passed away, a fact that was initially overlooked by the IBP Investigating Commissioner.
What is the significance of Canon 1 of the Code of Professional Responsibility?	Canon 1 requires lawyers to uphold the constitution, obey the laws of the land, and promote respect for law and legal processes, which Atty. Laeno violated through his deceptive actions.
How does Canon 10 relate to this case?	Canon 10 requires lawyers to be candid, fair, and act in good faith towards the court, which Atty. Laeno violated by presenting a false deed of sale as evidence.
What does Canon 12 emphasize?	Canon 12 directs lawyers to assist in the speedy and efficient administration of justice, which Atty. Laeno violated by filing multiple lawsuits to delay legal proceedings.
What was the outcome for Atty. Romeo R. Robiso?	The case against Atty. Romeo R. Robiso was dismissed for insufficiency of evidence.

The Supreme Court’s resolution serves as a stern reminder to all members of the bar regarding their ethical obligations and the serious consequences of violating the Code of Professional Responsibility. This decision reinforces the judiciary’s commitment to upholding the integrity of the legal profession and ensuring that lawyers act with honesty, fairness, and candor in all their dealings.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: ATTY. FERDINAND S. AGUSTIN VS. ATTY. DOMINGO C. LAENO, ET AL., A.C. No. 8124, March 19, 2019