196 SCRA 10 – Legal Ethics – A lawyer shall do no falsehood

In 1966, Atty. Viola assisted Felicidad Alvendia et al in filing a petition against Teodoro Chavez where he
sought to have the Alvendias be declared as bona fide lessees in a land controversy. Said petition was
dismissed because of nonappearance by the Alvendias.

In 1977, Atty. Viola assisted same clients in applying for an original registration of title over the same
land in controversy in 1966. In said application, Atty. Viola insisted that his clients were the true owners
of said land because they acquired it by sale from Teresita Vistan way back in 1929.

Chavez then filed a disbarment case against Atty. Viola. Chavez said that because of the conflicting
claims that Viola prepared in behalf of his clients, he had willingly aided in and consented to the pursuit,
promotion and prosecution of a false and unlawful application for land registration, in violation of his
oath of office as a member of the Bar.

ISSUE: Whether or not Atty. Viola is in violation of the Lawyer’s Oath.

HELD: Yes. Viola alleged in an earlier pleading that his clients were merely lessees of the property
involved. In his later pleading, he stated that the very same clients were owners of the same property.
One of these pleadings must have been false; it matters not which one. Worse, he offered no
explanation as regards the discrepancy.

A lawyer owes honesty and candor to the courts. It cannot be gainsaid that candidness, especially
towards the courts, is essential for the expeditious administration of justice. Courts are entitled to
expect only complete candor and honesty from the lawyers appearing and pleading before them. Atty.
Viola was suspended for 5 months.