7. Virgilio Mapalad, Sr. vs Atty.

Anselmo Echanez

AC # 10911, June 6, 2017

FACTS: Before the Integrated Bar of the Philippines (IBP) is a disbarment case filed by Virgilio J. Mapalad, Sr.
against respondent-lawyer Atty. Anselmo S. Echanez, for failure to comply with the MCLE requirements. The
respondent’s act of deliberately and unlawfully misleading the courts, parties and counsels concerned into
believing that he had complied with the Mandatory Continuing Legal Education (MCLE) requirements, when in
truth he had not, is a serious malpractice and grave misconduct in violation of the Lawyer’s Oath, Canon 1,
Rule 1.01 and Canon 10, Rule 10.01 of the Code of Professional Responsibility when he falsified his MCLE
Compliance Number. The IBP Commission on Bar Discipline (IBP-CBD), after thorough investigation, and
careful evaluation of pieces of evidence submitted by the complainant (respondent opted not to heed the
directive of the Commission to file comment and position papers), recommended that Atty. Anselmo S.
Echanez be disbarred and his name be stricken from the Roll of Attorneys, which was adopted and approved
by the IBP Board of Governors.

ISSUE: Whether or not Atty. Anselmo Echanez should be meted the ultimate penalty of disbarment.

HELD: YES. The SC DISBARRED Atty. Echanez from the practice of law.

Respondent violated Bar Matter No. 850. The Lawyer’s Oath in Rule 138, Section 3 of the Rules of
Court requires commitment to obeying laws and legal orders, doing no falsehood, and acting with fidelity to
both court and client, among others. A lawyer shall uphold the constitution, obey the laws of the land and
promote respect for law and legal processes (Canon 1), he shall not engage in unlawful, dishonest, immoral or
deceitful conduct (Rule 1.01), he owes candor, fairness and good faith to the court (Canon 10), he shall not do
any falsehood, nor consent to the doing of any in court, nor shall he mislead, or allow the court to be misled
by any artifice (Rule 10.01), he owes fidelity to the cause of his client and shall be mindful of the trust and
confidence reposed upon him (Canon 17), and he shall serve his client with competence and diligence (Canon
18).