AC 10564; (November, 2017) (Digest)
A.C. No. 10564. November 7, 2017. MANUEL L. VALIN AND HONORIO L. VALIN, Complainants, v. ATTY. ROLANDO T. RUIZ, Respondent.
FACTS
Complainants Manuel and Honorio Valin, surviving children of spouses Pedro and Cecilia Valin, alleged that their father Pedro died in 1992. Years later, they discovered that a parcel of land originally registered under their father’s name had been transferred to respondent Atty. Rolando T. Ruiz, their father’s godson. The transfer was effected through a Deed of Absolute Sale dated July 15, 1996, purportedly executed by Pedro and Cecilia. The complainants asserted the deed was a falsification, as Pedro was already deceased and Cecilia was abroad at that time. They pointed to respondent as the author, being the sole beneficiary who caused the registration of the land under his name.
In his defense, respondent claimed he purchased the land in 1989 from Rogelio Valin, another son, who allegedly represented his parents. He denied knowledge of the 1996 deed’s execution, attributing the forgery to Rogelio, and stated he merely instructed his housemaid to retrieve the new title from the Register of Deeds. The Integrated Bar of the Philippines Commission on Bar Discipline (IBP-CBD) found respondent liable and recommended a two-year suspension, which the IBP Board of Governors adopted.
ISSUE
Whether respondent Atty. Rolando T. Ruiz is administratively liable for violations of the Lawyer’s Oath and the Code of Professional Responsibility in relation to the falsified deed of sale.
RULING
Yes, respondent is administratively liable. The Supreme Court affirmed the IBP’s findings and imposed a two-year suspension. The legal logic rests on the principle that a lawyer must uphold the law and act with honesty, both professionally and personally. The Court found respondent’s defense implausible. As an experienced lawyer, he knew or should have known the requirements for a valid sale, including the necessity of a special power of attorney when the owner is abroad. His claim of purchasing the land in 1989 without any written document and his subsequent acceptance and registration of a deed executed in 1996—years after the vendor’s death—demonstrate gross negligence and bad faith.
The Court emphasized that the presumption that the beneficiary of a falsified document is its author applies here. Respondent failed to rebut this presumption. His act of instructing his housemaid to retrieve the title further indicates his direct involvement in the transaction’s consummation. By utilizing the falsified deed to obtain title, respondent engaged in conduct involving dishonesty and deceit, violating Rule 1.01 (prohibiting unlawful conduct) and Rule 10.01 (requiring candor and fairness) of the Code of Professional Responsibility. Such actions erode public trust in the legal profession. The suspension serves to preserve the integrity of the bar and deter similar misconduct.