Lacsamana v. De la Peña
REITERATIONFacts
The Antecedents: Complainant Jose Lacsamana charged Municipal Judge Meljohn de la Peña with violating his lawyer's oath and duty under Rule 138, Section 20(d) of the Rules of Court. The charge stemmed from the respondent's alleged introduction of a spurious "Escritura de Compraventa Absoluta" as evidence in civil cases where he represented the defendants. Lacsamana alleged that a verification of the notary public's register showed the deed was entered as Doc. 91, page 95, series of 1939, but this entry pertained to an affidavit by Ireneo Machete, not the "compraventa" document. Procedural History: The case originated from an administrative complaint filed by Jose Lacsamana against Municipal Judge Meljohn de la Peña before the Supreme Court. The Petition: The administrative complaint alleged that the respondent, while acting as counsel, presented a spurious "Escritura de Compraventa Absoluta" in civil cases. The complainant based his allegation on a discrepancy found in the National Archives regarding the notary public's register, which indicated that the deed was entered as Doc. 91, page 95, series of 1939, a number that actually corresponded to an affidavit of Ireneo Machete. The complainant branded the "compraventa" document as spurious.
Issue(s)
Whether the discrepancy in the notarial register entry for the "Escritura de Compraventa Absoluta" is sufficient to establish that the document is spurious and that the respondent judge, in his capacity as counsel, committed a violation of his oath and duty. Whether a prima facie case has been established to warrant further investigation into the administrative complaint.
Ruling
The Supreme Court dismissed the administrative complaint against Municipal Judge Meljohn de la Peña, holding that no prima facie case had been established to warrant further investigation.
Ratio Decidendi
On Issue 1: The Court held that a discrepancy in the notarial register, where a document is entered as Doc. 90 and another as Doc. 91, does not automatically render the "Escritura de Compraventa Absoluta" simulated or spurious. The Court emphasized that such a numerical difference, by itself, is insufficient to prove the document's fraudulent nature. Furthermore, even assuming the document was infirm, the complainant failed to allege or prove that the respondent judge, in his former capacity as counsel, was aware of this infirmity. The mere presentation of the document without knowledge of its alleged defect does not constitute a violation of the lawyer's oath or professional duty. On Issue 2: The Court found that the allegations and evidence presented by the complainant did not establish a prima facie case against the respondent judge. A prima facie case requires sufficient evidence that, if unrebutted, would be sufficient to establish the facts alleged. In this instance, the discrepancy in the notarial entries, without proof of the respondent's knowledge of any defect in the document, did not meet this threshold. Consequently, further investigation was deemed unwarranted, and the administrative complaint was dismissed.
Main Doctrine
The Court held that a mere discrepancy in the numbering of a notarial entry, where a document is recorded as Doc. 90 while another is Doc. 91, does not, by itself, establish that the document is simulated or spurious. Furthermore, even if the document were infirm, the complainant must allege and prove that the respondent judge, in his capacity as counsel, knew of this infirmity and intentionally presented the document as evidence in court. Without such allegations and proof, no prima facie case is established, warranting the dismissal of the administrative complaint.