A.C. No. 5839, August 22, 2006
Arturo C. Sampana, Complainant, vs. Atty. Edgardo J. Angara and Atty. Demaree J.B. Raval, Respondents.

FACTS

Complainant Arturo C. Sampana, a journalist, filed a disbarment complaint against respondents, incumbent Senator Edgardo J. Angara and Atty. Demaree Raval. He alleged that the respondents, through their alleged publicist Raymond Burgos and in conspiracy with another journalist, Robert Rivero, induced him to execute false affidavits and fabricate stories to implicate several high-profile individuals, including First Gentleman Miguel Arroyo and Senators Joker Arroyo and Juan Flavier, in various irregularities. The scheme purportedly aimed to support Senator Panfilo Lacson and was promised financial reward and publication support for Sampana’s book. A meeting was arranged at the Westin Philippine Plaza on August 22, 2001, where Sampana claimed he was presented to Atty. Raval and instructed on the content of the affidavits. Sampana later recanted, expressing remorse for his involvement in the plot to manufacture evidence.
The respondents denied all allegations. They asserted that the meeting at the hotel was merely a legal consultation regarding a separate libel case filed against Sampana and Rivero, and that the topics of drug trafficking or fabricated affidavits were never discussed. They presented evidence, including affidavits from Burgos and others, to refute Sampana’s narrative and highlight his inconsistent statements and motives, suggesting the complaint was a retaliatory act.

ISSUE

Whether respondents Atty. Edgardo J. Angara and Atty. Demaree J.B. Raval should be held administratively liable for gross misconduct and violation of the Code of Professional Responsibility based on the allegations of instigating the fabrication of evidence.

RULING

The Court dismissed the complaint and absolved the respondents of any administrative liability. The burden of proof in disbarment proceedings rests on the complainant, and the evidence must be clear, convincing, and preponderant. The Court found that Sampana failed to meet this heavy burden. His allegations were primarily based on his own uncorroborated affidavit and statements, which were contradicted by the evidence presented by the respondents. The Court gave weight to the respondents’ consistent denial and the supporting affidavits that provided a plausible, innocent explanation for the meeting—a legal consultation on a pending libel case.
The ruling emphasizes that while the Court will discipline lawyers for misconduct, it will also protect them from unfounded accusations. A lawyer’s reputation is paramount, and disgruntled individuals cannot use the disciplinary machinery as a tool for vengeance. Sampana’s evidence was deemed insufficient to overcome the presumption of innocence accorded to the respondents. Consequently, the complaint was denied for lack of merit.