A.M. No. 457-MJ. May 3, 1974. JOSE LACSAMANA, complainant, vs. MUN. JUDGE MELJOHN DE LA PEÑA, respondent.
FACTS

Complainant Jose Lacsamana filed an administrative complaint against Municipal Judge Meljohn de la Peña, who was then acting as a private counsel in two civil cases for recovery of property before the Court of First Instance. Lacsamana alleged that Judge de la Peña, representing the defendants, introduced into evidence a document titled “Escritura de Compraventa Absoluta.” This deed appeared to have been notarized by Notary Public Enrique Sibucao on April 30, 1939, and recorded as Doc. No. 91, Page 95, Series of 1939. Lacsamana subsequently verified the notarial register at the National Archives and discovered that the entry for Doc. No. 91, Page 95, Series of 1939, pertained to an entirely different document—an affidavit of one Ireneo Machete. Based on this discrepancy, Lacsamana branded the compraventa document as spurious and charged the respondent with violating his lawyer’s oath and duties by allegedly employing means inconsistent with truth and honor.
In his comment, Judge de la Peña disclaimed any knowledge or belief that the document was fraudulent. He submitted an affidavit from Perfecto Adobo, an heir of the original vendor, who stated that he had identified the document in court as part of his deceased father’s papers and that it was surrendered to the defendant upon the sale of the land. The respondent also pointed out that the annexes to the complaint showed the compraventa was entered as Doc. No. 90, while the Machete affidavit was Doc. No. 91, and argued this minor numerical discrepancy could not be attributed to him as counsel.

ISSUE

Whether respondent Judge Meljohn de la Peña should be held administratively liable for allegedly presenting a spurious document in court, in violation of his oath and professional duties.

RULING

The Supreme Court dismissed the administrative complaint, holding that no prima facie case was established to warrant further investigation. The Court’s legal logic centered on the insufficiency of the evidence to prove scienter or bad faith on the part of the respondent. The mere discrepancy in the notarial register entry—where the compraventa was recorded as Doc. No. 90 and the affidavit as Doc. No. 91—did not, by itself, conclusively prove the document was simulated or spurious. Even assuming arguendo that the document was indeed invalid, the complainant failed to allege, much less substantiate, the crucial element that the respondent lawyer knew of such infirmity at the time he presented it in court. Administrative liability for misconduct requires proof of malicious intent or conscious disregard of ethical duties. The respondent’s defense, supported by an affidavit from a relevant heir identifying the document, further negated any presumption of fraudulent intent. Absent clear evidence of knowledge and willful participation in the presentation of false evidence, no ethical breach could be sustained. The Court thus found no basis to proceed with the charges.