FACTS:

Siao Aba, Miko Lumabao, Almasis Lauban, and Benjamin Danda filed an administrative complaint against lawyers Salvador De Guzman Jr., Wenceslao "Peewee" Trinidad, and Andresito Fornier. The complainants claimed that the respondents instigated and filed fabricated criminal complaints against them for syndicated illegal recruitment and estafa. They alleged that De Guzman persuaded them to file the case in exchange for money and assured them that his group, including Trinidad, Fornier, and the Go Tian Brothers, were untouchable. The complainants received phone calls from the respondents urging them to pursue the case, but when they expressed their intention to withdraw, they were offered money to continue. As a result, the respondents orchestrated the filing of fabricated charges against them in Iligan City.

Trinidad claimed that Montesclaros's syndicate included some of their members as respondents to divert suspicion, and that his wife was a victim of a fabricated criminal charge of illegal recruitment. Fornier denied knowing any of the complainants and claimed that he was included in the case for acting as defense counsel for victims of an extortion racket led by Montesclaros. De Guzman filed a motion to dismiss the complaint, stating that the attached counter-affidavits and affidavit of complaint were spurious and that he had no participation in the preparation of the criminal complaint.

During the mandatory conference hearings, none of the complainants appeared to substantiate their allegations. The Investigating Commissioner recommended the dismissal of charges against Trinidad and Fornier but found enough basis to hold De Guzman administratively liable and recommended a two-month suspension.

Complainants filed a motion to dismiss the complaint against Trinidad and Fornier, stating that they were not involved in the alleged illegal recruitment activities. The Investigating Commissioner recommended the dismissal of charges against Trinidad and Fornier due to lack of merit.

However, the Investigating Commissioner found that De Guzman failed to deny the allegations in the Letter-Complaint or provide an explanation. The Board of Governors of the Integrated Bar of the Philippines adopted the recommendation to dismiss the charges against Trinidad and Fornier but increased the penalty for De Guzman to a two-year suspension from the practice of law due to his attempt to file illegal recruitment cases as a means to extort money.

ISSUES:

1. Whether Trinidad, Fornier, and De Guzman should be administratively disciplined based on the allegations in the complaint.

2. Whether the documents submitted by complainants are credible.

3. Whether the allegations of complainants lack material details to prove their communication with De Guzman.

4. Whether the letter allegedly sent by De Guzman to Cotabato City Councilor Orlando Badoy is credible.

5. Whether the documents submitted by the complainants in support of their complaint against De Guzman are credible.

6. Whether the complainants were able to prove their allegations of misconduct against De Guzman.

7. Whether De Guzman should be held liable for the charges against him.

8. Whether or not the Supreme Court can reverse the decision of the Board of Governors of the Integrated Bar of the Philippines if the complainants did not appeal within fifteen (15) days from notice.

9. Whether or not the charges against Attys. Wenceslao "Peewee" Trinidad and Andresito Fornier should be dismissed for lack of merit.

10. Whether or not the charges against Atty. Salvador P. De Guzman, Jr. should be dismissed for lack of merit.

RULING:

1. The charges against Trinidad and Fornier are dismissed.

2. The charges against De Guzman are also dismissed.

3. The documents submitted by complainants are not credible. They submitted a Joint Counter-Affidavit and Affidavit of Complaint purportedly subscribed and sworn to before a prosecutor. However, the Office of the City Prosecutor of Iligan issued a Certification denying the submission of this document by complainants. Complainants deceived and misled the authorities by submitting falsified documents, which gives doubt to the credibility of the other documents submitted.

4. The allegations of complainants lack material details to prove their communication with De Guzman. They failed to provide information such as the mobile number used by De Guzman, the existence of a warrant for their arrest, and their occupation or profession. Complainants did not attend any mandatory conference to substantiate their allegations, casting doubt on the credibility of their claims.

5. The letter allegedly sent by De Guzman to Orlando Badoy is not credible. There are material discrepancies in the signatures of De Guzman in his Affidavit of Clarification and in the purported letter. Complainants did not explain how they obtained a copy of the letter and did not present the recipients to authenticate it. The Investigating Commissioner gave weight to the letter, but it cannot be relied upon due to the lack of authentication.

6. The court finds that the documents submitted by the complainants are not credible.

7. The complainants failed to prove their allegations of misconduct against De Guzman. They were not able to discharge their burden of proof and did not appear in the mandatory conference proceedings to substantiate their claims.

8. De Guzman is found not liable for the charges against him.

9. The Supreme Court has the authority to reverse the decision of the Board of Governors of the Integrated Bar of the Philippines even if the complainants did not appeal within fifteen (15) days from notice.

10. The charges against Attys. Wenceslao "Peewee" Trinidad and Andresito Fornier are dismissed for utter lack of merit.

11. The charges against Atty. Salvador P. De Guzman, Jr. are also dismissed for utter lack of merit.

PRINCIPLES:

• An attorney enjoys the legal presumption of innocence until proven otherwise.

• The burden of proof rests upon the complainant in disbarment proceedings.

• Preponderance of evidence is required in suspension or disbarment proceedings.

• The equipoise doctrine mandates a decision in favor of the respondent when the evidence is evenly balanced or there is doubt on which side the evidence preponderates.

• The burden of proof rests on the complainants to establish the authenticity of the documents submitted and the credibility of their allegations.

• Falsification of documents and deception undermine the credibility of the complainants.

• Lack of material details and failure to attend mandatory conferences weaken the credibility of the allegations.

• In evaluating evidence, discrepancies, lack of authentication, and failure to explain the source of documents diminish their reliability.

• Legal presumption of innocence: De Guzman enjoys the legal presumption that he committed no crime or wrongdoing.

• Burden of proof: Complainants have the burden of proof to prove their allegations of misconduct against De Guzman.

• Preponderance of evidence: In disbarment proceedings, preponderance of evidence is required to merit an administrative penalty.

• Equipoise doctrine: Even if the evidence of the parties are evenly balanced, the court must rule in favor of the respondent according to the equipoise doctrine.

• Termination of case: Under Section 12(c) of Rule 139-B, an administrative case is deemed terminated if the penalty imposed by the Board of Governors is less than suspension or disbarment, unless the complainant files a petition with the court within 15 days from notice.

• The Supreme Court has the power to review and reverse decisions of the Board of Governors of the Integrated Bar of the Philippines.

• Charges against a lawyer shall be dismissed if there is an utter lack of merit.