AC 6198; (September, 2006) (Digest)
G.R. No. A.C. No. 6198 ; September 15, 2006
Renato M. Maligaya, complainant, vs. Atty. Antonio G. Doronilla, Jr., respondent.
FACTS
Complainant Renato M. Maligaya filed an administrative case against respondent Atty. Antonio G. Doronilla, Jr. for unethical conduct. The charge stemmed from a hearing in a civil case for damages where Atty. Doronilla, as counsel for the defendants, manifested in open court that there was an agreement between the parties to mutually withdraw their respective cases, which allowed complainant to retire and receive his pension. The presiding judge ordered Atty. Doronilla to reduce this manifestation to writing.
During the subsequent investigation by the IBP Commission on Bar Discipline, Atty. Doronilla admitted that no such written or formal agreement actually existed. He defended his statement by claiming it was merely a tactic or a “sort of question” intended to foster an amicable settlement among the parties, who were all military comrades. He argued that his false statement caused no actual prejudice to the case or the complainant.
ISSUE
Whether or not Atty. Doronilla violated the Code of Professional Responsibility by making a false statement in open court.
RULING
Yes, the Supreme Court found Atty. Doronilla guilty of violating the lawyer’s oath and the Code of Professional Responsibility. The Court emphasized that a lawyer’s duty of candor, fairness, and good faith to the court is paramount. Canon 10, Rule 10.01 explicitly prohibits a lawyer from doing any falsehood or misleading the court.
The Court rejected Atty. Doronilla’s defense that his falsehood was a mere settlement gambit. It held that a lawyer’s duty to the court to employ only truthful and honorable means is absolute and admits of no exception, even when the intent is to promote settlement. His subsequent admission that no agreement existed confirmed the falsity of his court manifestation. His obstinate refusal to acknowledge the wrongfulness of his act compounded his ethical breach.
However, the Court modified the penalty recommended by the IBP. While the IBP suggested suspension from government military service, the Court clarified that its disciplinary authority extends only to the practice of law. Consequently, Atty. Doronilla was suspended from the practice of law for three (3) months, with a stern warning that a repetition of the same or similar act would be dealt with more severely.