G.R. No. A.C. No. 1092 October 27, 1983
VICENTE LIM, complainant, vs. ATTORNEY FRANCISCO G. ANTONIO, respondent.

FACTS

Complainant Vicente Lim charged respondent attorney Francisco G. Antonio with violating the law by allegedly changing his name without judicial authority. The complaint asserted that respondent’s birth certificate listed his name as “Paquito Lim Antonio Clemente,” but he used “Francisco G. Antonio” in his professional and academic life, constituting an illegal alias and falsification.
In his answer, respondent denied the charge, explaining he had always used the name Francisco Antonio from birth, with “Paquito” merely being a nickname recorded on his birth certificate. He submitted extensive documentation, including his academic diplomas, CPA certification, and Supreme Court admission records, all bearing the surname Antonio. Respondent highlighted that this was a second, identical disbarment complaint filed by the same complainant, with the first having been dismissed by the Court in 1971. He attributed the complaint to malice, noting he had previously acted as a prosecutor in cases where complainant was convicted.

ISSUE

Whether respondent attorney Francisco G. Antonio should be disciplined for illegally using an alias name in violation of Commonwealth Act No. 142 , as amended.

RULING

The Court dismissed the complaint and censured the complainant. The legal logic rests on the absence of any violation by respondent and the demonstrably malicious intent behind the filing. Respondent proved through consistent documentary evidence—spanning his education, professional certifications, and bar admission—that he had legitimately used “Francisco G. Antonio” as his correct and only name throughout his life. The entry “Paquito” was credibly shown to be a mere nickname, not a legally adopted surname requiring a court order for change. The use of his formal given name, Francisco, did not constitute the use of an “alias” prohibited under the law.
Crucially, the Court found the complaint was filed in bad faith as an instrument of retaliation. The Solicitor General’s report established that complainant’s motive arose from resentment due to respondent’s prior role as a successful prosecutor and opposing counsel in cases against him. This was the second such unfounded proceeding, and complainant had also previously failed in similar criminal cases against respondent on the same grounds. The Court emphasized that the judicial process must not be weaponized for personal vengeance. While dismissing the complaint against the innocent respondent, the Court held the complainant accountable for his abuse of process, warranting the penalty of censure to uphold the dignity of the legal profession and the integrity of its disciplinary mechanisms.