Wednesday, August 21, 2013

LEGAL ETHICS; Disbarment Proceedings: Burden of Proof Always Rests on the Complainant

"The burden of proof in disbarment and suspension proceedings always rests on the shoulders of the complainant. The Court exercises its disciplinary power only if the complainant establishes the complaint by clearly preponderant evidence that warrants the imposition of the harsh penalty. As a rule, an attorney enjoys the legal presumption that he is innocent of the charges made against him until the contrary is proved. An attorney is further presumed as an officer of the Court to have performed his duties in accordance with his oath.

In this case, complainants failed to discharge their burden of proving respondents' administrative liability. Granting that the certification of the QCCPO of the actual date of receipt of the subject NLRC decision has prima facie credence, this Court finds it is not sufficient to hold respondents administratively liable as contended by complainants.


While there is incongruity between said certification and the records of respondents' law firm as to when the subject NLRC decision was actually received by the latter, there is no clear and convincing evidence presented by complainants that respondents maliciously made it appear that they received the decision on a date ten days later than what is reflected on the records of the QCCPO. Complainants would like to convince this Court that the only logical explanation as to the discrepancy is that Calucag, a secretary under the employ of respondents, was ordered by respondents to stamp a much later date instead of the actual date of receipt for the purpose of extending by ten-day period within which to file a Motion for Reconsideration under the NLRC Rules of Procedure. Clearly, such claim is merely anchored on speculation and conjecture and not backed by any clear preponderant evidence necessary to justify the imposition of administrative penalty on a member of the Bar." (Joven and Rasing v. Attys. Cruz and Magsalin, A.C. No. 7686, 31 July 2013)

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