The Supreme Court ruled that omitting the specific amount of damages in the prayer of a complaint does not automatically constitute unethical conduct. The Court emphasized that the key is whether the lawyer intended to deceive the court or evade the payment of proper docket fees. In this case, because the complaint clearly referenced the amounts of the unpaid checks, and the Clerk of Court did not find any underpayment of fees, the lawyers were not found to have violated the Code of Professional Responsibility. The decision underscores the importance of proving deceitful intent in disbarment cases and protects lawyers from accusations of unethical behavior based on mere technicalities.

A Case of Unpaid Checks: Did Lawyers Skirt Proper Fees?

The disbarment complaint against Attys. E. Hans A. Santos and Agnes H. Maranan stemmed from a civil case they filed on behalf of their client. The complainant, Atty. Alfredo L. Villamor, Jr., alleged that the respondents deliberately omitted the amount of damages sought in the prayer of their complaint to avoid paying the correct docket fees. This, he argued, was a violation of the Code of Professional Responsibility and warranted disbarment, citing the doctrine established in Manchester Development Corporation, et al. v. Court of Appeals.

The respondents countered that their complaint was primarily for specific performance and injunction, as many of the checks involved were not yet due when the case was filed. They also argued that the Manchester doctrine had been modified since its initial pronouncement. The Integrated Bar of the Philippines (IBP) investigated the matter and found no unethical conduct on the part of the respondents. The IBP Commissioner noted that the complaint contained clear references to the amounts of the unpaid checks, and the Clerk of Court had not been deceived or made any error in assessing the filing fees. The IBP Board of Governors adopted this recommendation and dismissed the complaint.

The Supreme Court’s analysis hinged on whether the respondents acted with deceitful intent. The Court reiterated that disbarment is a serious penalty, and the burden of proof lies with the complainant to establish professional misconduct by clearly preponderant evidence. The central issue was whether the omission of the specific amount of damages in the prayer constituted an unethical practice, thereby violating the Code of Professional Responsibility. The Court turned to Canon 1, Rule 1.01, which states:

“A lawyer shall not engage in unlawful, dishonest, immoral, or deceitful conduct.”

Additionally, Canon 10, Rules 10.01, 10.02, and 10.03 emphasize candor, fairness, and good faith towards the court:

“A lawyer owes candor, fairness, and good faith to the Court.
Rule 10.01 – A lawyer shall not do any falsehood, nor consent to the doing of any in court, nor shall he mislead by any artifice.”

The Court emphasized that, in this particular case, the element of “deceitful conduct” was not present. The prayer in the complaint clearly referenced paragraph 2.27, which listed the dates, numbers, and amounts of the checks in detail. The prayer also mentioned the amount of P9.5 million representing the value of the checks that had already become due. These explicit references negated the claim that the respondents intentionally omitted the amount of damages to mislead the court.

Furthermore, the Clerk of Court did not reassess the filing fees or require additional payments, despite the complainant’s motion to dismiss the case for alleged underpayment of docket fees. The Court also noted that the case was fundamentally an action for specific performance and injunction. The complaint sought to compel the delivery of the checks, an accounting of those already encashed, and a restraint against further negotiation or encashment. Thus, even if the respondents’ reference to paragraph 2.27 did not fully comply with the Manchester doctrine, it was not sufficient grounds for disbarment. There was no evidence that the respondents defrauded or misled the Clerk of Court, or that they maliciously disguised their complaint to evade proper docket fees.

The Court emphasized that the presumption of innocence remains in the absence of proof of misconduct, dishonesty, or falsehood. The complaint against Attys. E. Hans A. Santos and Agnes H. Maranan was, therefore, dismissed for lack of merit. This decision highlights the importance of demonstrating clear intent to deceive or defraud when alleging unethical conduct against a lawyer. It also confirms the lawyer’s duty of candor, fairness, and good faith towards the court, underscoring the high ethical standards expected of legal professionals. In conclusion, a technical error is not enough to warrant a disbarment case. The intent must be malicious and there must be some form of a deceitful scheme.

FAQs

What was the key issue in this case?	The key issue was whether the respondents’ omission of the specific amount of damages in the prayer of the complaint constituted unethical conduct and a violation of the Code of Professional Responsibility.
What is the Manchester doctrine?	The Manchester doctrine, from Manchester Development Corporation v. Court of Appeals, frowns upon omitting the amount of damages in the prayer of a complaint to evade correct filing fees.
What did the IBP find in this case?	The IBP found that the respondents did not commit any violation of the code of professional ethics, as there was no showing that the Clerk of Court had been deceived.
What was the basis of the disbarment complaint?	The disbarment complaint was based on the allegation that the respondents intentionally omitted the amount of damages in the prayer of the complaint to avoid paying the proper docket fees.
What is Canon 1, Rule 1.01 of the Code of Professional Responsibility?	Canon 1, Rule 1.01 states that a lawyer shall not engage in unlawful, dishonest, immoral, or deceitful conduct.
Did the Supreme Court find the respondents guilty of unethical conduct?	No, the Supreme Court agreed with the IBP’s findings and held that the respondents did not commit any unethical conduct.
What evidence did the Court consider in its decision?	The Court considered the clear references to the amounts of the checks in the complaint’s prayer, the absence of any reassessment of fees by the Clerk of Court, and the nature of the case as one for specific performance and injunction.
What is the standard of proof in disbarment cases?	The standard of proof in disbarment cases is that the complainant must establish professional misconduct by clearly preponderant evidence.
Was there any proof that the respondents disguised the case?	No, there was no proof that the respondents disguised their complaint as an action for specific performance and injunction to evade the payment of the proper docket fees.

This case serves as a reminder that allegations of unethical conduct against lawyers must be supported by clear and convincing evidence of deceitful intent. While lawyers are expected to be candid and fair in their dealings with the court, mere technical errors or omissions do not automatically warrant disciplinary action.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: ATTY. ALFREDO L. VILLAMOR, JR. VS. ATTYS. E. HANS A. SANTOS AND AGNES H. MARANAN, A.C. No. 9868, April 22, 2015