A.C. No. 8261. March 11, 2015 (Case Brief / Digest)

**Title: Campugan and Torres vs. Tolentino et al.**


In January 2007, Jessie T. Campugan and Robert C. Torres initiated a civil lawsuit to annul a transfer certificate title in Quezon City, attaching an affidavit of adverse claim and notice of lis pendens to the title. Their lawsuit was against several individuals and the Register of Deeds in Quezon City. Atty. Federico S. Tolentino was representing the opposing party. During the lawsuit, the parties agreed to an amicable settlement, which led to the withdrawal of the complaint and counterclaim through a motion filed by their then-legal representative, Atty. Victorio, Jr..

Upon the court’s approval of the withdrawal, Campugan and Torres could not contact Atty. Victorio, Jr. and discovered at the Register of Deeds that new annotations were made on the title, seemingly to cancel their adverse claim and lis pendens based on the court’s decision and a letter-request by a defendant.

Feeling aggrieved, Campugan and Torres filed an appeal to the Land Registration Authority (LRA) challenging the cancellation. Meanwhile, unable to get a response from Atty. Victorio, Jr., they filed disbarment complaints against attorneys Tolentino, Victorio, Cunanan, Quilala, and Caluya for allegedly falsifying court orders and other documents leading to the cancellation.


1. Whether the actions of the respondents constituted misconduct warranting disbarment.
2. Whether Atty. Victorio, Jr. and Atty. Tolentino, Jr. conspired with each other and with other respondents to unduly influence the cancellation of the adverse claim and notice of lis pendens.
3. Whether there was any neglect or abandonment of duty by Atty. Victorio, Jr. towards the complainants.
4. Whether the duties performed by the Registers of Deeds (Atty. Quilala, Atty. Cunanan, and Atty. Caluya) in cancelling the annotations were regular and within their ministerial duties.

**Court’s Decision:**

The Supreme Court dismissed the disbarment complaints for being without merit. It held that the actions of the Registers of Deeds were within their ministerial duties and responsibilities, as their role does not extend to questioning the veracity or legality of court orders presented to them for registration purposes. The court also found no evidence of conspiracy between Atty. Victorio, Jr. and Atty. Tolentino, Jr. or any misconduct on their part. Instead, it was noted that the complainants themselves partook in the amicable settlement of their civil case. As for the alleged abandonment by Atty. Victorio, Jr., the court found that his engagement ended with the resolution of the civil case, and any expectation for him to handle subsequent matters without a separate engagement was unreasonable.


This case reiterated the principle that a lawyer’s duty in representing their client ends with the termination of the case or engagement unless explicitly stated otherwise. It underscored the principle that the duties of Registers of Deeds are ministerial in nature, focusing on ensuring documents conform to legal requirements without delving into their substantive validity.

**Class Notes:**

– **Lawyer’s Duty and Engagement:** Termination of case or explicit agreement defines the scope. Absence of further engagement relieves the lawyer from subsequent related duties.
– **Ministerial Duties of Registers of Deeds:** Focus on document compliance with legal form and requisites, without questioning the document’s substantive legality.
– **Conspiracy in Legal Ethics:** Requires clear and convincing evidence beyond mere conjecture or assumption.
– **Professional Misconduct and Disbarment:** Charges must be supported by substantial evidence demonstrating the lawyer’s unfitness to practice law.

**Historical Background:**

This case adds to the body of jurisprudence on the ethical responsibilities of lawyers towards their clients and the scope of ministerial actions by Registers of Deeds. It highlights the procedural due diligence required in legal representations and the importance of clear agreements on the scope of a lawyer’s duties. It also reflects the judicial system’s checks on the ethical conduct of legal professionals through disbarment proceedings, emphasizing the principle that not every action taken by a lawyer, which a client deems unfavorable, constitutes ethical misconduct warranting disciplinary actions.


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