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    Mapalad v. Echanez

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    April Digas
    This case involves a disbarment proceeding against attorney Anselmo Echanez. The Supreme Court ruled that Echanez should be disbarred for including a false Mandatory Continuing Legal Education (MCLE) compliance number in court pleadings on multiple occasions, despite not having fulfilled his MCLE requirements. The MCLE Office confirmed he had no compliance. His actions misled courts and clients. Additionally, he repeatedly failed to obey court orders. Given his misconduct and two prior sanctions, the Court affirmed the disbarment recommendation to prevent further practice of law.

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    Mapalad v. Echanez

    Uploaded by

    April Digas
    26 views2 pages
    This case involves a disbarment proceeding against attorney Anselmo Echanez. The Supreme Court ruled that Echanez should be disbarred for including a false Mandatory Continuing Legal Education (MCLE) compliance number in court pleadings on multiple occasions, despite not having fulfilled his MCLE requirements. The MCLE Office confirmed he had no compliance. His actions misled courts and clients. Additionally, he repeatedly failed to obey court orders. Given his misconduct and two prior sanctions, the Court affirmed the disbarment recommendation to prevent further practice of law.

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    This case involves a disbarment proceeding against attorney Anselmo Echanez. The Supreme Court ruled that Echanez should be disbarred for including a false Mandatory Continuing Legal Education (MCLE) compliance number in court pleadings on multiple occasions, despite not having fulfilled his MCLE requirements. The MCLE Office confirmed he had no compliance. His actions misled courts and clients. Additionally, he repeatedly failed to obey court orders. Given his misconduct and two prior sanctions, the Court affirmed the disbarment recommendation to prevent further practice of law.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    26 views2 pages

    Mapalad v. Echanez

    Uploaded by

    April Digas
    This case involves a disbarment proceeding against attorney Anselmo Echanez. The Supreme Court ruled that Echanez should be disbarred for including a false Mandatory Continuing Legal Education (MCLE) compliance number in court pleadings on multiple occasions, despite not having fulfilled his MCLE requirements. The MCLE Office confirmed he had no compliance. His actions misled courts and clients. Additionally, he repeatedly failed to obey court orders. Given his misconduct and two prior sanctions, the Court affirmed the disbarment recommendation to prevent further practice of law.

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    Disbarment case; MCLE requirements

    Mapalad v. Echanez
    A.C. No. 10911, June 6, 2017
    TIJAM, J.

    DOCTRINE:

    “In using a false MCLE compliance number in his pleadings, respondent also put his own clients at
    risk. Such deficiency in pleadings can be fatal to the client's cause as pleadings with such false
    information produce no legal effect.”

    FACTS:

     In various cases, Atty. Echanez indicated his Mandatory Continuing Legal Education
    (MCLE) Compliance No. II-0014038 without indicating the date of issue thereof.

     Upon inquiry with the MCLE Office, complainant discovered that respondent had no MCLE
    compliance yet.

     The MCLE Office then issued a Certification dated September 30, 2009, stating that
    respondent had not yet complied with his MCLE requirements for the First Compliance
    Period and Second Compliance Period.

     Complainant argues that respondent's act of deliberately and unlawfully misleading the
    courts, parties, and counsels concerned into believing that he had complied with the MCLE
    requirements when in truth he had not, is a serious malpractice and grave misconduct.

     The IBP Board of Governers then issued a resolution that Atty. Anselmo Echanez is
    hereby DISBARRED and his name stricken from the Roll of Attorneys.

    ISSUE:

    Should respondent be administratively disciplined based on the allegations in the complaint and
    evidence on record?

    RULING:

    YES, at any rate, respondent's acts of misconduct are clearly manifest.

    First. It was clearly established that respondent violated Bar Matter No. 850 20. No less than the
    MCLE Office had issued a certification stating that respondent had not complied with the first
    and second compliance period of the MCLE.

    Second. Despite such non-compliance, respondent repeatedly indicated a false MCLE


    compliance number in his pleadings before the trial courts. 22 In indicating patently false
    information in pleadings filed before the courts of law, not only once but four times, as per
    records, the respondent acted in manifest bad faith, dishonesty, and deceit. In so doing, he
    indeed misled the courts, litigants - his own clients · included - professional colleagues, and all
    others who may have relied on such pleadings containing false information.

    Third. The respondent also repeatedly failed to obey legal orders of the trial court, the IBP-CBD,
    and also this Court despite due notice.

    Taken altogether, considering respondent's act of using a false MCLE compliance number in his
    pleadings 35 , his repeated failure to obey legal Orders, and the fact that he had already been
    sanctioned twice by this Court On separate cases, We are constrained to affirm the IBP Board of
    Governors' Resolution No. XXI-2014-685, recommending his disbarment to prevent him from
    further engaging in legal practice.

    WHEREFORE, respondent Anselmo S. Echanez is hereby DISBARRED from the practice of


    law, and his name is ORDERED STRICKEN FROM THE ROLL OF ATTORNEYS. Let a copy
    of this Decision be entered in his record as a member of the Bar; and let notice of the same be
    served on the Integrated Bar of the Philippines, and on the Office of the Court Administrator for
    circulation to all courts in the country.

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