AC 7062; (September, 2006) (Digest)
G.R. No. A.C. No. 7062; September 26, 2006
RENERIO SAMBAJON, RONALD SAMBAJON, CRISANTO CONOS, and FREDILYN BACULBAS, complainants, vs. ATTY. JOSE A. SUING, respondent.
FACTS
Complainants were among the workers who prevailed in a consolidated labor case for illegal dismissal and unfair labor practice against Microplast, Inc. A final and executory Labor Arbiter decision ordered their reinstatement with full backwages. A writ of execution was subsequently issued. However, the Labor Arbiter later dismissed the case as to seven complainants, including the four herein, based on individual Release Waiver and Quitclaim documents dated February 27, 2004, which were purportedly signed and sworn to before him. Complainants denied ever signing these documents or receiving any consideration. They filed this disbarment complaint, alleging respondent Atty. Suing, counsel for Microplast, colluded with his clients to present these spurious documents to frustrate the writ’s execution. A related criminal complaint for falsification was also filed.
ISSUE
Whether respondent Atty. Jose A. Suing should be held administratively liable for his actions concerning the execution of the Release Waiver and Quitclaim documents.
RULING
Yes, respondent is suspended from the practice of law for one year. The Court found his defense and the IBP Commissioner’s recommendation of mere negligence untenable. During the IBP investigation, respondent admitted under oath that he was present when the quitclaims were signed before the Labor Arbiter. However, he also explicitly stated he did not personally know the complainants and could not confirm if the persons who appeared were indeed the real complainants. This admission is fatal. A lawyer, as an officer of the court, has a duty to ensure the integrity of judicial processes. By facilitating the execution of quitclaims by persons whose identities he did not verify, despite knowing the documents would be used to terminate a final judgment in favor of specific individuals, respondent engaged in deceit and gross misconduct. His actions directly subverted the execution of a final judgment, violating his oath and the Code of Professional Responsibility. The Court emphasized that the duty to the administration of justice is paramount and outweighs duty to a client. Respondent’s conduct, which undermined a final labor ruling, constituted a serious transgression warranting suspension.