Caronan vs. Caronan

Assumption of another's identity and academic credentials to obtain a law degree and gain admission to the Bar constitutes gross dishonesty and lack of good moral character warranting the striking of the impostor's name from the Roll of Attorneys, perpetual disqualification from admission, and prohibition from practicing law, notwithstanding the impostor's potential to later complete academic requirements, because the practice of law is a privilege limited to citizens of good moral character, and the fraudulent act itself demonstrates inherent unfitness for the profession.

Siblings Patrick A. Caronan (born August 5, 1976) and Richard A. Caronan (born February 7, 1975) completed secondary education at Makati High School. Patrick obtained a Bachelor of Science in Business Administration from the University of Makati in 1997 and thereafter worked for Philippine Seven Corporation (PSC), operator of 7-11 Convenience Stores, eventually rising to Store Manager in 2009. Richard enrolled at the Pamantasan ng Lungsod ng Maynila in 1991 but transferred to the Philippine Military Academy in 1992; discharged in 1993 without completing a college degree, he relocated to Nueva Vizcaya in 1997 and never returned to formal schooling.

• The Imposture: In 1999, Richard informed Patrick that he had enrolled in a law school in Nueva Vizcaya. Their mother subsequently informed Patrick that Richard passed the 2004 Bar Examinations using Patrick's name and academic records from the University of Makati to enroll at St. Mary's University's College of Law in Bayombong, Nueva Vizcaya. Complainant initially dismissed these reports, anticipating no adverse consequences.
• Discovery and Confirmation: Patrick confirmed the identity theft in 2006 upon viewing a Certificate of Admission to the Bar bearing his name displayed at Richard's office in Taguig City. In May 2009, the National Bureau of Investigation (NBI) summoned Patrick regarding criminal complaints (qualified theft and estafa) filed against Richard, who had been practicing under the name "Atty. Patrick A. Caronan." NBI records established that Richard, when arrested on August 31, 2012, identified his parents as Porferio Ramos Caronan and Norma Atillo and his spouse as Rosana Halili-Caronan, whereas official National Statistics Office records show "Patrick A. Caronan" married to Myrna G. Tagpis. Photographs of Richard upon arrest matched IBP records of "Atty. Patrick A. Caronan."
• Consequences for Complainant: Richard's use of Patrick's identity in various criminal activities—including gun-running, illegal possession of explosives, violation of Batas Pambansa Bilang 22, and fraudulent land sales—caused Patrick to fear for his safety, suffer professional embarrassment, and ultimately resign from his employment at PSC.
• Respondent's Defense: Richard denied all allegations and invoked res judicata based on the dismissal of CBD Case No. 09-2362 (filed by Joseph G. Agtarap) by the IBP Board of Governors and the termination of A.C. No. 10074 by the Supreme Court. He alleged that complainant was being used by Brigadier General Joselito M. Reyes and Mrs. Loyda L. Reyes to harass and malign him due to pending complaints he had filed against them before the Ombudsman.

• Falsification and Identity Theft: Complainant maintained that respondent falsely assumed his name, identity, and academic records to enroll in law school and take the Bar Examinations, thereby obtaining admission to the Bar through fraud.
• Lack of Qualification: Complainant argued that respondent never completed a bachelor's degree, rendering him ineligible ab initio for admission to the Bar under Section 6, Rule 138 of the Rules of Court.
• Moral Unfitness: Complainant contended that respondent's fraudulent acts demonstrated a fundamental lack of good moral character and common honesty essential for membership in the legal profession.
• Prejudice: Complainant asserted that respondent's use of his identity in criminal activities caused him to lose his employment, suffer reputational harm, and fear for his personal safety.

• Res Judicata: Respondent argued that the issue of his identity could no longer be raised as it had already been resolved in CBD Case No. 09-2362, which the IBP dismissed, and which this Court declared closed and terminated in A.C. No. 10074.
• Denial: Respondent denied all allegations of identity theft and false representation.
• Harassment: Respondent alleged that complainant was being used by the Reyes spouses to humiliate, disgrace, malign, discredit, and harass him because he had filed administrative and criminal complaints against them before the Ombudsman.

• Striking Off the Roll: Whether the IBP erred in ordering that the name "Patrick A. Caronan" be stricken off the Roll of Attorneys.
• Disqualification from Admission: Whether the IBP erred in ordering that the name "Richard A. Caronan" be barred from being admitted to the Bar.

• Striking Off the Roll: The IBP committed no error. Clear and overwhelming evidence established that Richard falsely assumed Patrick's name, identity, and academic records to enroll in law school and take the Bar Examinations. The real Patrick A. Caronan never pursued legal studies; therefore, the Roll of Attorneys entry under that name corresponds to an impostor and must be deleted.
• Disqualification from Admission: The IBP committed no error. Richard never satisfactorily completed a pre-law course as required by Section 6, Rule 138 of the Rules of Court, having left the Philippine Military Academy in 1993 without obtaining a bachelor's degree. His fraudulent assumption of his brother's identity demonstrated a fundamental lack of good moral character—specifically, the absence of common honesty essential for membership in the Bar. The practice of law being a privilege limited to citizens of good moral character, Richard is permanently disqualified from admission.

• Good Moral Character Requirement — Good moral character is what a person really is, as distinguished from good reputation or from the opinion generally entertained of him; it includes at least common honesty and corresponds to objective reality rather than subjective self-assessment. The requirement is continuous and demands integrity in both personal and professional conduct. Here, respondent's assumption of his brother's identity and academic records demonstrated a patent lack of common honesty and moral fitness for the profession.
• Practice of Law as Privilege — Admission to the Bar and the practice of law constitute a privilege granted by the State only to citizens of proven good moral character, not a natural, absolute, or constitutional right available to all who demand it. Respondent's dishonesty renders him unfit for this privilege.
• Pre-Law Academic Requirements — Under Section 6, Rule 138 of the Rules of Court, no applicant may take the Bar Examinations unless he has pursued and satisfactorily completed a bachelor's degree in arts or sciences from an authorized and recognized university or college before commencing the study of law. Respondent's failure to complete any college degree rendered his law degree and Bar admission void ab initio.

• "Good moral character is what a person really is, as distinguished from good reputation or from the opinion generally entertained of him, the estimate in which he is held by the public in the place where he is known. Moral character is not a subjective term but one which corresponds to objective reality. The standard of personal and professional integrity is not satisfied by such conduct as it merely enables a person to escape the penalty of criminal law. Good moral character includes at least common honesty."
• "The practice of law, after all, is not a natural, absolute or constitutional right to be granted to everyone who demands it. Rather, it is a privilege limited to citizens of good moral character."

• In the Matter of the Admission to the Bar of Argosino, 316 Phil. 43 (1995) — Cited for the principle that the practice of law is a privilege limited to citizens of good moral character.
• In the Matter of the Disqualification of Bar Examinee Haron S. Meling in the 2002 Bar Examinations and for Disciplinary Action as Member of the Philippine Shari'a Bar, Atty. Froilan R. Melendrez, B.M. No. 1154, June 8, 2004 — Cited for the definition of good moral character as including common honesty and corresponding to objective reality.
• Lizaso v. Amante, 275 Phil. 1 (1991) — Cited for the trust relation existing between lawyer and client and between lawyer and court.

• Section 6, Rule 138, Rules of Court — Mandates that no applicant for admission to the Bar Examination shall be admitted unless he has pursued and satisfactorily completed a bachelor's degree in arts or sciences before beginning the study of law.
• Rule 7.03, Code of Professional Responsibility — Requires lawyers to uphold the integrity and dignity of the legal profession.

Maria Lourdes P.A. Sereno (Chief Justice), Antonio T. Carpio, Presbitero J. Velasco, Jr., Teresita J. Leonardo-De Castro, Arturo D. Brion, Diosdado M. Peralta, Lucas P. Bersamin, Mariano C. Del Castillo, Jose Portugal Perez, Jose Catral Mendoza (On Official Leave), Bienvenido L. Reyes (On Official Leave), Estela M. Perlas-Bernabe, Marvic M.V.F. Leonen, Francis H. Jardeleza, Alfredo Benjamin S. Caguioa.