Patrick Caronan v.

Richard Caronan
A.C. No. 11316
July 12, 2016
Group 1 – Mendoza

Complainant: Patrick Caronan

Respondent: Richard Caronan

SUMMARY
Complainant Patrick Caronan filed a complaint before the Commission on Bar Discipline (CBD) of the Integrated
Bar of the Philippines, against respondent and his sibling, Richard Caronan for assuming complainant’s identity in
order to take the Bar Examinations and be admitted to the practice law. Respondent also purportedly used
Patrick’s identity to perpretrate crimes and commit unlawful activities. Resolving the complaint, IBP
recommended that (1) “Patrick A. Caronan” be stricken off the Roll of Attorneys and (2) the name “Richard A.
Caronan” be barred from being admitted to the Bar. The Court affirmed IBP’s recommendation based on
respondent’s lack of a pre-law degree and unfit moral character.

RELEVANT PROVISION
Sec. 6, Rule 138 of the Rules of Court.

No applicant for admission to the bar examination shall be admitted unless he presents a certificate that
he has satisfied the Secretary of Education that, before he began the study of law, he had pursued and
satisfactorily completed in an authorized and recognized university or college, requiring for admission thereto
the completion of a four-year high school course, the course of study prescribed therein for a bachelor's degree in
arts or sciences with any of the following subject as major or field of concentration: political science, logic,
english, spanish, history, and economics.

FACTS
 Patrick Caronan and Richard Caronan are siblings
 Patrick Caronan completed a degree in Business Administration in the University of Makati, while
Richard Caronan did not complete his stay in the Philippine Military Academy
 In 1999, Richard enrolled in St. Mary’s University’s College of Law in Nueva Vizcaya and subsequently
passed in the 2004 Bar Examinations using complainant’s name and college records
 Complainant brushed these aside as he did not anticipate any adverse consequences to him
 However, in May 2009, complainant was ordered to report to the head office of the PSC in Mandaluyong
City where he was informed by the NBI of respondent’s involvement in a case for qualified theft and
estafa
 Problems continued to arise in 2013 where complainant found out that Richard victimized clients and was
arrested for gun-running activities, illegal possession of explosives and violation of Batas Pambansa
Bilang (BP) 22, all using the complainant’s name in the process
 Due to these, complainant decided to file a complaint-affidavit before the IBP-CPD to stop respondent’s
alleged use of the former’s name and identity, and illegal practice of law
 IBP-CPD found respondent guilty of illegally and falsely assuming complainant’s name, identity and
academic records and ordered that (a) the name "Patrick A. Caronan" be stricken off the Roll of
Attorneys; and (b) the name "Richard A. Caronan" be barred from being admitted to the Bar.

ISSUES
1. W/N IBP erred in ordering that the name "Patrick A. Caronan" be stricken off the Roll of Attorneys – NO
2. W/N IBP erred in ordering that the name "Richard A. Caronan" be barred from being admitted to the Bar -
NO

RATIO
1. Complainant has established by clear and overwhleming evidence that he si the real “Patrick A.
Caronan”
  Proven through complainant’s NSO records showing that “Patrick A. Caronan” is married to
Myrna G. Tagpis and not to Rosana Halili-Caronan
 The photograph taken of respondent when he was arrested as “Richard A. Caronan” on August
16, 20120 shows the same person in the IBP records of “Atty. Patrick A. Caronan”
 Complainant submitted his transcript of records in the University of Makati showing his picture,
a copy of his highschool yearbook and NBI clearances

2. Respondent violated Section 6, Rule 138 of the Rules of Court

 No applicant for admissition to the Bar Examination shall be admitted unless he had pursued
and satisfactorily completed a pre-law course
 Respondent never completed his degree in PMA where he was discharged in 1993

3. Respondent is unfit for admission to the Bar

 The practice of law is a privilege limited to citizens of good moral character
 Respondent exhibited his dishonesty and utter lack of moral fitness to be a member of the Bar
when he assumed the name, identity, adnd school records of his own brother
 Respondent and his acts do not have a place in the legal profession where one of the primary
duties of its members is to uphold its integrity and dignity