G.R. No. 10555, July 31, 2018
Evelyn T. Goopio vs. Atty. Ariel D. Maglalang

FACTS

Complainant Evelyn Goopio, working abroad, engaged the services of Atty. Ariel Maglalang in 2005 to resolve property disputes over twelve parcels of land in Negros Occidental. She executed a General Power of Attorney in his favor. Goopio alleged that Atty. Maglalang informed her a petition for rescission was filed in court, requested and received ₱400,000.00 for this purpose, presented an official receipt, and subsequently billed her for legal services rendered between December 2006 and April 2007. She later discovered no such petition was ever filed, leading to the revocation of the power of attorney and a demand for restitution.
Atty. Maglalang denied all allegations. He claimed he never met Goopio in 2005 or 2006, did not accept a power of attorney, and never received any money. He asserted that Goopio’s sister, his client Ma. Cecilia Consuji, surreptitiously used his name and forged documents to collect money from Goopio. He cited the dismissal of related criminal complaints for falsification and estafa by the City Prosecutor as proof of the allegations being hearsay and baseless.

ISSUE

Whether Atty. Ariel D. Maglalang should be held administratively liable for deceit and gross misconduct in violation of the Code of Professional Responsibility.

RULING

Yes, Atty. Maglalang is administratively liable. The Supreme Court affirmed the IBP’s finding, imposing a three-year suspension and ordering restitution of ₱400,000.00. The Court found a lawyer-client relationship was established through the documentary evidence, including the General Power of Attorney, billing statements, and the demand letter from Goopio’s counsel. Atty. Maglalang’s bare denials could not overcome this evidence. His failure to reply to the formal demand letter was deemed an admission of its contents.
The Court rejected his defense that Goopio’s sister orchestrated a scheme without his knowledge. His claim of forgery was unsubstantiated, and he failed to take any affirmative action, such as filing a case against the sister, to clear his name. The dismissal of the criminal complaints by the prosecutor did not bind the disbarment proceeding, as the standards of proof differ; administrative cases require only substantial evidence. His acts of deceit—collecting a large sum for a non-existent case and misrepresenting the status of legal proceedings—constitute gross misconduct and a violation of his oath. Such conduct erodes public trust in the legal profession and warrants severe disciplinary action.