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RENATO M. MALIGAYA v. ATTY. ANTONIO G. DORONILLA

FACTS:

Atty. Antonio G. Doronilla, Jr., an officer of the Judge Advocate General's Service, is charged with unethical conduct for uttering a falsehood in open court during a hearing of Civil Case No. Q-99-38778. Atty. Doronilla claimed that there was an agreement between the complainant and the defendants to withdraw the case if the complainant also withdrew all the other cases filed against the defendants. However, presiding Judge Reynaldo B. Daway ordered Atty. Doronilla to substantiate his statements by filing the appropriate pleading, but he failed to do so. Complainant Renato Maligaya filed a complaint against Atty. Doronilla with the Integrated Bar of the Philippines (IBP), accusing him of misleading the court through misrepresentation of facts.

ISSUES:

  1. Whether Atty. Doronilla violated the Code of Professional Responsibility and the lawyer's oath by stating a falsehood in court.

  2. Whether Atty. Doronilla's false statement caused actual prejudice to the complainant.

RULING:

  1. Atty. Doronilla is found guilty of violating Canon 10, Rule 10.01 of the Code of Professional Responsibility, which prohibits lawyers from doing any falsehood, consenting to the doing of any falsehood in court, or misleading the court by any artifice. By stating untruthfully in open court that there was an agreement to withdraw the case, Atty. Doronilla breached his ethical duty to behave with truth and honor. He also violated the lawyer's oath to do no falsehood in court.

  2. The explanation submitted by Atty. Doronilla, claiming that his statements were meant as a question and a gambit to settle the case amicably, is deemed a specious attempt to evade responsibility. Even if his intention was to settle the case without trial, it does not justify speaking falsely in court. Lawyers have a duty to employ only truthful means consistent with truth and honor. Atty. Doronilla's offense is within the scope of Section 27, Rule 138 of the Rules of Court.

  3. The IBP's recommendation for Atty. Doronilla's suspension from the government military service is not appropriate because the purpose of this administrative case is to determine his liability as a member of the legal profession. Therefore, he is suspended from the practice of law for two months. This penalty is mitigated by Atty. Doronilla's admission of his falsehood, the absence of material damage to the complainant, and the fact that it is his first offense. However, his unrepentant attitude calls for a suspension to allow him time to recognize his error and correct his false perception that compromise justifies sacrificing truthfulness in court.

PRINCIPLES:

  • Lawyers have a duty to behave at all times in a manner consistent with truth and honor when participating in the dispensation of justice. Canon 10 and Rule 10.01 of the Code of Professional Responsibility require lawyers to be candid, fair, and act in good faith towards the court.

  • Lawyers should not do any falsehood or consent to the doing of any falsehood in court. They should not mislead or allow the court to be misled by any artifice.

  • Upholding truth and honesty is a fundamental duty of lawyers. They should never seek to mislead the judge or any judicial officer through false statements of fact or law.