Young v. Batuegas
REITERATIONFacts
The Antecedents: Complainant Atty. Walter T. Young filed a disbarment complaint against Attys. Ceasar G. Batuegas, Miguelito Nazareno V. Llantino, and Franklin Q. Susa for allegedly committing deliberate falsehood and violating their lawyer's oath. The respondents were counsel for the accused in a murder case before the RTC of Manila, Branch 27. On December 13, 2000, respondents Batuegas and Llantino filed a Manifestation with Motion for Bail, alleging that their client had voluntarily surrendered and was under detention. Complainant verified with the NBI that the accused only surrendered on December 14, 2000, as evidenced by a Certificate of Detention. Procedural History: Respondent Susa, the Branch Clerk of Court, calendared the motion for December 15, 2000, despite alleged irregularities including lack of notice of hearing to the private complainant, violation of the three-day notice rule, and failure to attach the Certificate of Detention. The respondents lawyers argued that their client voluntarily surrendered and was detained, and that the complainant was not entitled to notice. Respondent Susa contended that he was not present when the motion was filed and that its inclusion in the calendar was authorized by the presiding judge. The Petition: The case was referred to the Integrated Bar of the Philippines (IBP) for investigation. The Investigating Commissioner recommended the suspension of Attys. Batuegas and Llantino for six months for deliberate falsehood, and the dismissal of the complaint against Atty. Susa for lack of merit. The IBP-Commission on Bar Discipline adopted and approved this recommendation.
Issue(s)
Whether respondents Attys. Batuegas and Llantino committed deliberate falsehood in their Manifestation with Motion for Bail. Whether respondent Atty. Susa is administratively liable for calendaring the motion despite alleged irregularities.
Ruling
The Supreme Court adopted the findings and recommendations of the Investigating Commissioner. Attys. Ceasar G. Batuegas and Miguelito Nazareno V. Llantino were found guilty of committing deliberate falsehood and were suspended from the practice of law for six (6) months. The complaint against Atty. Franklin Q. Susa was dismissed for lack of merit.
Ratio Decidendi
On the issue of deliberate falsehood by Attys. Batuegas and Llantino: The Court found that the respondents lawyers fell short of their duties. They allegedly concealed the truth by stating that the accused had voluntarily surrendered and was under detention on December 13, 2000, when in fact, the surrender and detention were only confirmed on December 14, 2000. This was deemed a deliberate ruse to mislead the court and contribute to injustice, constituting a violation of their lawyer's oath. The Court emphasized that a lawyer must be a disciple of truth and cannot conduct themselves at the expense of truth, even in defending a client's cause. The contention that the allegation was an ultimate fact to be proven later did not exonerate them, as the fact alleged on December 13, 2000, was demonstrably false at that time. The Court reiterated that knowingly alleging an untrue statement of fact in a pleading is a contemptuous conduct that warrants condemnation and disciplinary action. The lawyers' obligation includes observing procedural rules and not misusing them to defeat the ends of justice, including the requirement of reasonable notice of hearing for motions. On the administrative liability of Atty. Susa: The Court agreed with the Investigating Commissioner that respondent clerk of court should not be held administratively liable. This was because his action of including the Motion for Bail in the court's calendar was authorized by the presiding judge. While his administrative functions are vital to the administration of justice, his actions in this instance were performed in faithful performance of his ministerial duty, as directed by the judge. However, he was reminded of his duty to inform the judge of any conduct by lawyers contrary to established rules of procedure.
Main Doctrine
Lawyers are bound by their oath to do no falsehood nor consent to the doing of any in court, and must conduct themselves with all good fidelity as well to the courts as to their clients. Knowingly alleging an untrue statement of fact in a pleading is a contemptuous conduct that violates the lawyer's oath and warrants disciplinary action.