FACTS:
In November 2002, Flordeliza A. Madria sought the assistance of Atty. Carlos P. Rivera for the annulment of her marriage. Atty. Rivera assured her that she had a strong case and agreed to handle her case for a fee of P25,000. Madria returned to Atty. Rivera's office on November 19, 2002, where she signed the petition for annulment and paid an initial fee of P4,000. She continued to follow up on her case and was eventually informed by Atty. Rivera that her petition had been granted. He even provided her with a copy of the trial court's decision and certificate of finality.
However, it was later discovered that the documents given to Madria were fabricated. The Clerk of Court of the Regional Trial Court confirmed that the documents were not genuine. As a result, Madria faced criminal charges for violating the Philippine Passport Act. Atty. Rivera, on the other hand, denied the allegations and claimed that Madria had insisted on fabricating the documents, assuring him that they would remain confidential.
Upon investigation, the Integrated Bar of the Philippines (IBP) found Atty. Rivera guilty of violating his lawyer's oath. They recommended his disbarment, which was later adopted by the Court.
ISSUES:
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Whether or not the respondent violated his Lawyer's Oath by causing the simulation of court documents.
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Whether or not the respondent should be disbarred from the practice of law.
RULING:
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Yes, the respondent violated his Lawyer's Oath by causing the simulation of court documents.
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Yes, the respondent should be disbarred from the practice of law.
PRINCIPLES:
- A lawyer who causes the simulation of court documents violates the court and its processes, and betrays the trust and confidence reposed in him by his client, and must be disbarred to maintain the integrity of the Law Profession.