G.R. No. L-35113. March 25, 1975
Eugenio Cuaresma, petitioner, vs. Marcelo Daquis, PHHC, Cesar Navarro, Nicanor Guevarra, Sheriff of Quezon City or his Deputy and Judge Pacifico P. de Castro, respondents. Attorney Macario O. Directo, respondent.

FACTS

Petitioner Eugenio Cuaresma, through counsel Atty. Macario O. Directo, filed a petition for certiorari alleging he had no knowledge of the existence of Civil Case No. Q-12176 and that he was not given his day in court prior to the issuance of a demolition order against his house, constituting a violation of due process. The petition contained categorical assertions of ignorance regarding the case and the proceedings.
Upon receipt of the comments from the other respondents, the Supreme Court discovered that the allegations were false. It was established that Atty. Directo himself, as Cuaresma’s counsel, had written a letter concerning the case months earlier, filed a motion for intervention, and filed motions to quash the writ of execution and oppose the demolition. Furthermore, the petitioner had been given ample notice to vacate the premises. The Court required Atty. Directo to show cause why no disciplinary action should be taken for these deliberate falsehoods.

ISSUE

Whether Atty. Macario O. Directo should be held administratively liable for making false allegations of fact in a petition filed before the Supreme Court.

RULING

Yes, Atty. Directo is administratively liable. The Court found his explanation—that his client only lacked knowledge of the case from its filing in 1968 until after the 1970 decision—to be an unconvincing afterthought designed to explain away the patently false statements in the petition. The allegations as phrased were unequivocal claims of total ignorance of the case’s existence and of any opportunity to be heard, which the record conclusively disproved.
However, the Court, considering mitigating factors, imposed only a reprimand. It noted Atty. Directo’s profession of good faith and his awkward phrasing in both the petition and his compliance, which suggested carelessness or a lack of proficiency in English rather than a calculated intent to deceive. Nevertheless, the Court emphasized that candor and honesty in dealings with the judiciary are fundamental obligations of every lawyer. The reprimand serves as a warning for Atty. Directo to exercise utmost care and accuracy in preparing pleadings to avoid any doubt regarding his intellectual honesty. A copy of the resolution was ordered to be entered into his record.