A.C. No. 8667. February 3, 2016. INOCENCIO I. BALISTOY, Petitioner, vs. ATTY. FLORENCIO A. BRON, Respondent.
FACTS

Complainant Inocencio Balistoy filed a disbarment case against respondent Atty. Florencio Bron, counsel for the defendants in a civil case for damages. Balistoy alleged that Atty. Bron submitted pleadings containing falsified Community Tax Certificates (CTCs) for his clients. Verification from government offices showed the serial numbers of the CTCs were either not allotted to the issuing city or were issued to different localities. Furthermore, Balistoy accused Atty. Bron of submitting false medical certificates to justify his clients’ absences from court hearings. One certificate pertained to a vehicular accident, while another claimed a client was quarantined after arriving from Malaysia, which airport records did not corroborate.
Atty. Bron denied the allegations. He argued he did not procure the disputed CTCs or medical certificates and had no opportunity to verify their authenticity at the time. He claimed the complaint was a retaliatory act for his diligent representation. The Integrated Bar of the Philippines (IBP) Board of Governors initially dismissed the complaint for lack of merit, a decision which Balistoy elevated to the Supreme Court.

ISSUE

Whether Atty. Florencio Bron should be disbarred for allegedly submitting falsified documents and making false representations in court.

RULING

The Supreme Court denied the petition and dismissed the disbarment complaint, but reprimanded Atty. Bron for lack of due care. The Court emphasized that in disbarment proceedings, the burden of proof rests on the complainant, and the evidence must be clear, convincing, and preponderant. Balistoy failed to meet this burden. There was no direct, substantial evidence proving Atty. Bron personally fabricated the falsified CTCs or the questionable medical certificates. The mere submission of these documents by counsel, without proof of his personal knowledge of their falsity or his direct participation in their creation, is insufficient to establish ethical breaches like deceit or malpractice warranting disbarment.
However, the Court found Atty. Bron administratively liable for negligence in his notarial duty. As a notary public, he attested to the veracity of his clients’ signatures on the pleadings based on the presented CTCs. His failure to exercise due diligence in ensuring the authenticity of these documents—which exhibited discrepancies in issuance details—constituted carelessness. This lapse merited a reprimand to remind him of his duty to uphold the integrity of the notarial process. The Court concluded that while the evidence did not support the grave charge of disbarment, a lesser sanction was appropriate for his lack of caution.