G.R. No. A.C. No. 7329; November 27, 2013
Case Parties/Title: Spouses David and Marisa Williams, Complainants, vs. Atty. Rudy T. Enriquez, Respondent.

FACTS

Complainants Spouses David and Marisa Williams purchased a 2,000-square meter portion of a parcel of land owned by Josephine L. Verar, covered by Transfer Certificate of Title (TCT) No. T-19723, with the sale annotated on the title. On December 4, 2002, respondent Atty. Rudy T. Enriquez, representing his clients (Desiderio B. Ventolero, Francisco B. Ventolero, Ramon Verar, Martin Umbac, and Lucia Briones), filed a complaint for forcible entry against the Spouses Williams in the Municipal Circuit Trial Court (MCTC) of Bacong, Negros Oriental (Civil Case No. 390). The MCTC ruled in favor of Atty. Enriquez’s clients, finding that the Spouses Williams had forcibly taken possession of the land.
The Spouses Williams subsequently filed the present administrative complaint against Atty. Enriquez, charging him with dishonesty for allegedly making false statements in the forcible entry complaint and misleading the court. Specifically, they alleged that Atty. Enriquez: (1) falsely claimed the property was covered by an Original Certificate of Title (OCT) instead of a TCT; (2) falsely stated the owner’s name as “Josephine L. Veran” instead of “Josephine L. Verar”; (3) falsely claimed his clients were the lawful owners; (4) falsely asserted Verar was merely a trustee for his clients; and (5) fraudulently withheld the pages of TCT No. T-19723 that contained the annotation of the sale to the Spouses Williams.
In his defense, Atty. Enriquez argued, among other points, that the complaint was verified by his client, the MCTC decided in his clients’ favor, and the allegations were part of a privileged communication in a judicial proceeding.
The Integrated Bar of the Philippines (IBP) Investigating Commissioner found that Atty. Enriquez knowingly made untruthful statements and recommended a one-year suspension from the practice of law. The IBP Board of Governors adopted this recommendation.

ISSUE

Whether respondent Atty. Rudy T. Enriquez should be held administratively liable for dishonesty based on the alleged falsehoods in the forcible entry complaint he filed.

RULING

The Supreme Court SET ASIDE the IBP’s resolutions and DISMISSED the administrative complaint without prejudice.
The Court held that the alleged false statements—writing “OCT” instead of “TCT” (but with the same number T-19723) and “Veran” instead of “Verar”—were too trivial to warrant administrative sanction and could have been made inadvertently. Furthermore, the failure to attach the pages of the TCT showing the sale annotation to the Spouses Williams did not prejudice them because the issue in a forcible entry case is prior physical possession, not ownership. The Court emphasized that while disbarment proceedings assess a lawyer’s fitness, the factual merits of the related case may be examined; however, in this instance, the cited inaccuracies were minor and did not constitute a violation of the lawyer’s oath warranting suspension.