Facts: The subject of contention is Lot No. 636, originally owned by the spouses Apolinario Aggalut and Juliana Lodovico and titled under OCT No. 4564. This lot was sold in 1938 to Jeremias Dulay, and possession later transferred to his son, Jesus Dulay. In 1972, Pedro Aggalut (relative of the original owners) and Juanita Aggalut (sister of Apolinario) filed for the issuance of owners’ duplicates of titles through lawyer Mariano T. Bagasao. Subsequently, Pedro became the caretaker of Bagasao’s cattle ranch. On August 31, 1976, Bagasao had Pedro and his wife sign a document that would later be revealed as a “Deed of Confirmation of Sale with Absolute Quitclaim” in favor of Juanita Gonong, Bagasao’s wife, claiming the land had been sold to her by Pedro’s parents and that the purchase price had been paid in full.
Unaware of the manipulation, Pedro Aggalut contended that he neither appeared before the notarizing municipal judge nor had he ever met him. The deed’s registration did not link Bagasao and Gonong as husband and wife. The land was mortgaged to the Development Bank of the Philippines (DBP), yet bizarrely, a “Deed of Reconveyance & Resale Over Registered Land” was executed by Gonong in favor of Aggalut, which was also questioned for its authenticity.
The ownership conflict extended to Civil Case No. 2585, where Jesus Dulay contested the ownership of Lot No. 636 against the Bagasao spouses, resulting in an amicable settlement in Dulay’s favor. Aggalut later recanted his complaint against Bagasao, but an investigation revealed Aggalut was likely not entitled to ownership of the lot, making Dulay the logical complainant.
Issues:
1. Whether or not Bagasao engaged in unprofessional and unethical conduct in his dealings concerning Lot No. 636.
2. The validity of the “Deed of Confirmation of Sale with Absolute Quitclaim” signed by Pedro Aggalut.
3. The legitimacy of the “Deed of Reconveyance & Resale Over Registered Land” claimed to be executed by Gonong in favor of Aggalut.
Court’s Decision:
The Supreme Court resolved to severely reprimand Mariano T. Bagasao for his unethical manipulations regarding Lot No. 636. While Aggalut withdrew his complaint, the Court found that Bagasao’s maneuvers to acquire the lot were unmistakable and merited censure. Justice Makasiar opined that Bagasao should be disbarred for falsification of a public document and exploiting an ignorant man.
Doctrine:
A lawyer must conduct themselves with integrity and honesty. Unethical behavior that involves manipulation or deceit to acquire property is grounds for censure and may warrant disbarment.
Historical Background:
The case highlights the standard of professional conduct expected of lawyers in the Philippines. It underscores the legal profession’s duty to uphold justice and fairness, not just for their clients, but in their personal dealings as well. In the Philippines, the post-Marcos era has been marked by a heightened awareness and enforcement of ethical standards for public officials, including lawyers, to prevent abuses of power and regain public trust in the government and its institutions.
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