In Atty. Ferdinand S. Agustin v. Attys. Domingo C. Laeno, Romeo R. Robiso, and Reginaldo D. Bergado, the Supreme Court addressed the ethical responsibilities of lawyers, particularly concerning honesty, integrity, and adherence to the law. The Court suspended Atty. Laeno for five years for executing multiple deeds of sale with undervalued considerations and for introducing a false deed as evidence. This decision reinforces the principle that lawyers must uphold the integrity of the legal profession and act with candor and fairness towards the court.

Double Dealing and Deception: When Legal Ethics are Trampled

The case arose from a property sale agreement between Marcelina Agustin, represented by her daughter Perpetua, and Atty. Domingo C. Laeno. After the sale, Marcelina discovered that Atty. Laeno had executed two Deeds of Absolute Sale with different, undervalued considerations to evade proper tax payments. Atty. Laeno then used one of these fraudulent deeds as evidence in court. The Integrated Bar of the Philippines (IBP) initially recommended a two-year suspension for Atty. Laeno, but the Supreme Court increased this to five years, emphasizing the severity of his ethical violations. Atty. Reginaldo D. Bergado, who notarized both fraudulent deeds, was found to have passed away during the pendency of the investigation, effectively terminating any administrative action against him. Atty. Romeo R. Robiso was absolved due to insufficient evidence.

Atty. Laeno’s actions directly contravened the Code of Professional Responsibility, which mandates lawyers to uphold the law, maintain the integrity of the legal profession, and act with candor towards the court. His creation and use of two different deeds of sale to undervalue the property’s consideration demonstrated a clear intent to deceive and evade tax obligations. Furthermore, his attempt to introduce a fraudulent deed as evidence before the Supreme Court was a grave violation of his duty to the court. Lawyers are expected to be truthful and honest in their dealings, and any deviation from this standard can result in severe disciplinary actions.

The Supreme Court heavily relied on the following Canons of the Code of Professional Responsibility in its decision:

CANON 1 – A lawyer shall uphold the constitution, obey the laws of the land and promote respect for law and legal processes.

CANON 7 – A lawyer shall at all times uphold the integrity and dignity of the legal profession x x x.

CANON 10 – A lawyer owes candor, fairness and good faith to the court.

Atty. Laeno’s attempts to avoid eviction through multiple lawsuits further demonstrated a disregard for the efficient administration of justice, violating Canon 12 of the Code, which states:

Canon 12 – A lawyer shall exert every effort and consider it his duty to assist in the speedy and efficient administration of justice.

The Court emphasized that lawyers have a duty to abide by judgments, even when unfavorable, and should not engage in tactics that delay or obstruct the legal process. As stated in Lazareto v. Atty. Acorda:

[T]he 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 Court’s decision underscores the importance of maintaining the highest standards of ethical conduct within the legal profession. Attorneys must act with honesty, integrity, and fairness in all their dealings, and any deviation from these principles will be met with appropriate disciplinary measures. This case serves as a reminder that lawyers are not only legal professionals but also officers of the court, entrusted with upholding the law and promoting justice. Their conduct must always reflect the integrity and dignity of the legal profession.

FAQs

What was the key issue in this case?	The key issue was whether Atty. Laeno violated the Code of Professional Responsibility by executing multiple deeds of sale with undervalued considerations and presenting a false deed as evidence. The case also addressed the liability of the notary public, Atty. Bergado, for notarizing the fraudulent documents.
What was the Supreme Court’s ruling?	The Supreme Court suspended Atty. Laeno from the practice of law for five years due to his ethical violations. The case against Atty. Robiso was dismissed for insufficient evidence, and the case against Atty. Bergado was terminated due to his death.
What canons of the Code of Professional Responsibility were violated?	Atty. Laeno violated Canons 1, 7, 10, and 12 of the Code of Professional Responsibility. These canons pertain to upholding the law, maintaining the integrity of the legal profession, acting with candor towards the court, and assisting in the efficient administration of justice.
Why was the penalty against Atty. Laeno increased?	The Supreme Court increased the penalty because Atty. Laeno’s actions were a grave breach of ethical standards. The Court found his conduct to be a serious affront to the legal profession and the administration of justice.
What is the significance of this case?	This case reinforces the importance of ethical conduct for lawyers and the consequences of violating the Code of Professional Responsibility. It serves as a reminder that lawyers must act with honesty, integrity, and fairness in all their dealings.
What was Atty. Bergado’s involvement in the case?	Atty. Bergado notarized both fraudulent deeds of sale. However, he passed away during the investigation, which resulted in the termination of the administrative case against him.
What was Atty. Robiso’s role in the case?	Atty. Robiso represented Atty. Laeno in a related case. However, the IBP and the Supreme Court found insufficient evidence to hold him administratively liable for any misconduct.
Can a lawyer be disciplined for dishonesty?	Yes, lawyers can be disciplined for dishonesty, as it violates their ethical obligations under the Code of Professional Responsibility. Disciplinary actions can range from suspension to disbarment, depending on the severity of the misconduct.

This case demonstrates the Supreme Court’s commitment to upholding the ethical standards of the legal profession. Attorneys who engage in deceptive practices will face severe consequences, ensuring that the integrity of the legal system is maintained. The Court’s decision serves as a crucial reminder to all lawyers to act with honesty, integrity, and fairness in all their professional 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