Pineda, Marie Beatrice C.

1D -CLaw

Patrick A. Caronan v Richard A. Caronan

a.k.a Atty. Patrick A. Caronan
FACTS:
Complainant Patrick A. Caronan and respondent Richard A. Caronan are
siblings.

Both finished their secondary education at Makati High School. After

graduation,

complainant

enrolled

and

obtained

his

degree

in

Business

Administration at the University of Makati. Thereafter, complainant worked as a

Sales Associate for Philippine Seven Corporation and was married to Myrna G.
Tagpis. In 2009, complainant got promoted as a Store Manager of the 7-11 Store in
Muntinlupa. Meanwhie, after respondent finished his secondary education, he took
a year in college at Pamantasan ng Lungsod ng Maynila. He was then admitted to
the Philippine Military Academy but was later on discharged. Respondent helped
his father managed their familys car rental business instead and married Rosana.
In 1997, respondent with his wife and their three children moved to Nueva
Vizcaya.
In 1999, it was made known by the respondent to the complainant that the
former enrolled in a law school in Nueva Vizcaya. In 2004, complainant was
informed by his mother that respondent was able to pass the Bar examinations
and that respondent used complainants name and college credentials to enroll
and to obtain his degree in Law at St. Marys University. In 2006, complainant was
able to confirm that respondent was using the formers name Patrick A. Caronan
and identity, as this was displayed on the Certificate of Admission to Bar at
respondents office. Nevertheless, complainant did not confront respondents use
of his name, college credentials, and identity as he did not anticipate any adverse
consequence to him.
However, sometime in May 2009, complainant was ordered to report to the
head office of Philippine Seven Corporation. Upon his arrival he was informed that
the National Bureau of Investigation was requesting his presence at its office.
Accordingly, complainant appeared before the Anti-Fraud and Computer Crimes
Division of the NBI. Complainant was interviewed and was asked to identify
pertinent documents on his and respondents identity and credentials due to
respondents involvement in a case for qualified theft and estafa filed by Mr.
Joseph G. Agtarap, who was one of the principal sponsors at respondents
wedding.
With the foregoing information, complainant tried to inform others of the
mistaken identity, that he is the real Patrick A. Caronan. However, despite
efforts, respondents use of the name Atty. Patrick A. Caronan continued to hound
him. Philippine Seven Corporation received a letter from Quasha Ancheta Pena &
Nolasco Law Offices, requesting that they be furnished of complainants contact

Pineda, Marie Beatrice C.

1D -CLaw

details or, in the alternative, schedule a meeting with complainant to discuss

certain matters concerning the respondent. Respondent was also involved in the
unauthorized selling of land in Taguig City and in almost victimizing his church
members with the use of complainants name Atty. Patrick A. Caronan.
Complainant also learned of respondents arrest in relation to gun-running
activities, illegal possession of explosives, and violation of Batas Pambansa Bilang
22. Complainant feared for his own safety and security upon learning of
respondents ways. He also became the subject of conversations among his
colleagues, which leaded him to resign from his job. Eventually he filed a
Complaint-Affidavit against respondent. In his defense, respondent denied all
allegations against him. He contended that the issue on his identity can no longer
be brought to the courts as it was already resolved in an earlier administrative
case filed by Mr. Agtarap, which was declared closed and terminated. Moreover,
respondent alleged that complainant was used by a certain Mr. Reyes and his
spouse in order to malign, discredit, and humiliate him due to respondents filing
of several administrative and criminal cases against the couple before the
Ombudsman.
IBP on its report and recommendation found respondent guilty of illegally and
falsely assuming complainants name, identity, and academic records, considering
the circumstances and evidences presented, that 1.) complainant was married to
Rosana Halili-Coronan, yet, based on the Marriage Certificate issued by the NSO,
Patrick A. Caronan was married to a certain Myrna G. Tagpis ; 2.) where it was
shown that the photograph taken by the NBI of respondent Richard A. Caronan
was the same person in the photograph in the IBP records of Atty. Patrick A.
Caronan. Complainant, on the other hand, presented sufficient proofs with
regards to his real name and identity. In view of the foregoing, IBP recommended
for the name Patrick A. Coronan to be stricken off the Roll of Attorneys and that
the name be barred from being admitted as a member of the bar.
ISSUE: 1.) Whether or not the IBP erred in ordering that the name Patrcik A.
Caronan be stricken off the Roll of Attorneys; 2.) Whether or not the name
Richard A. Caronan be barred from being admitted to the bar

HELD: The court found no cogent reason to disturb the findings and
recommendations of the IBP for the following reasons:
1. The proofs with regards to the real name and identity of the complainant and
the circumstances and the evidences presented against the respondent

Pineda, Marie Beatrice C.

1D -CLaw

indisputably confirmed that the latter falsely used complainant's name,

identity, and school records to gain admission to the Bar. Since complainantthe real "Patrick A. Caronan" never took the Bar Examinations, the IBP
correctly recommended that the name "Patrick A. Caronan" be stricken off
the Roll of Attorneys.
2. Under Section 6, Rule 138 of the Rules of Court, no applicant for admission
to the Bar Examination shall be admitted unless he had pursued and
satisfactorily completed a pre-law course.
Respondent never completed his college degree. While he enrolled at the
Pamantasan ng Lungsod ng Maynila, he left a year later and entered the
Philippine Military Academy, where he was discharged without graduating.
Clearly, respondent has not completed the requisite pre-law degree.
The Court does not discount the possibility that respondent may later on
complete his college education and earn a law degree under his real name.
However, his false assumption of his brother's name, identity, and
educational records renders him unfit for admission to the Bar. 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.