G.R. No. A.C. No. 5050. September 20, 2005
Felisa M. Angeles, et al., Complainants, vs. Atty. Roberto L. Figueroa, Respondent.

FACTS

Complainants were defendants in a civil case where respondent Atty. Figueroa was opposing counsel. The trial court ordered respondent to file an answer to a request for admission. After delays, respondent filed a manifestation stating he had already mailed the answer via registered mail, attaching registry receipt nos. 799, 800, and 801 from the Tanza Post Office as proof. Complainants and the court did not receive the mailing.
An investigation by the Philippine Postal Corporation’s Inspection Service, via a letter from the Tanza Postmaster, revealed that the letters bearing those specific registry receipt numbers were never actually posted at the Tanza Post Office on the stated date. The trial court, finding respondent had deceived it, held him in contempt and imposed a fine. Complainants then filed this disbarment case, alleging respondent used falsified registry receipts, constituting deceit, malpractice, and a violation of the Code of Professional Responsibility.

ISSUE

Whether respondent Atty. Figueroa should be administratively disciplined for allegedly using falsified registry receipts in a judicial proceeding.

RULING

No. The Supreme Court dismissed the complaint for lack of merit. The ruling hinged on the burden of proof in disbarment proceedings, which rests on the complainant and must be established by clear, convincing, and preponderant evidence. The Court found the evidence insufficient to prove respondent knowingly used falsified documents.
The Court credited respondent’s explanation that the non-delivery resulted from anomalies at the Tanza Post Office, including the non-remittance of fees by a since-removed postmaster, which caused officially issued receipts to be logged but corresponding mail not to be dispatched. Testimony from postal officials confirmed these operational anomalies existed. The Court noted the contempt order was based on the fact of non-receipt and deception of the court, but it did not constitute a definitive finding that respondent himself fabricated the receipts. Without clear proof that respondent was the source of the falsification or acted with fraudulent intent—as opposed to being a victim of postal malpractice—the quantum of proof required for administrative sanction was not met. Thus, the complaint was dismissed.