Sta. Ana v. Cortes A.C. No. 6980, 30 August 2017

Facts: Atty. Cortes was left with the care and maintenance of several properties either owned or under the administration of Atty. Casal since the latter’s death. Sta. Ana, herein complainant, alleged that Atty. Cortes abused his authority and engineered the sale/transfer of the said properties. IBP found that the latter used a falsified document and did actively participate in the sale of such properties.
On the other hand, Atty. Cortes asserted that all the criminal complaints against him had been dismissed and the information instituted therefore had been withdrawn by the Department of Justice (DOJ).

Issue: Whether or not Atty. Cortes should be held administratively liable

Decision: Yes. Atty. Cortes acted with deceit by using falsified documents to effect the transfer of properties. The dismissal of the criminal complaints against him is of no moment since administrative cases against lawyers are sui generis. Atty. Cortes is ordered:
1. Suspended for one (1) year;
2. Revoked notarial commission; and
3. Disqualified from being commissioned as a notary public for two (2) years

Credit to:
Case Digest Author
Lenard L. Bautista
Arellano University School of Law

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