SC disbars lawyer over fake MCLE record

The Supreme Court of the Philippines has disbarred a lawyer for falsifying his Mandatory Continuing Legal Education (MCLE) compliance number in court pleadings, ruling that the act constituted serious dishonesty and gross violation of professional ethics.

In a per curiam decision released Thursday, the SC en banc ordered the disbarment of Jose R. Hidalgo for violating the Code of Professional Responsibility and Accountability (CPRA).

Hidalgo represented a defendant in a malicious prosecution case before the Regional Trial Court Branch 153 Biñan when he submitted an answer that included an MCLE compliance number, which is required for practicing lawyers.

However, the opposing counsel questioned the validity of the MCLE record and submitted a certification from the MCLE Office stating that Hidalgo had not complied with MCLE requirements for the relevant compliance periods.

The trial court later ordered Hidalgo to explain why he should not be cited in contempt for using a false compliance number, and also referred the matter to the Integrated Bar of the Philippines and MCLE Office for administrative investigation.

After review, the IBP found that Hidalgo knowingly used a false MCLE compliance number, committing serious dishonesty, fraud, deceit, and misrepresentation, and recommended his disbarment. The Supreme Court adopted the recommendation.

The Court cited Bar Matter No. 850, which requires lawyers to complete 36 hours of continuing legal education every three years, and Bar Matter No. 1922, which mandates disclosure of MCLE compliance details in all court pleadings.

“The act of indicating patently false information in pleadings filed before the courts constitutes bad faith and dishonesty, and shows blatant disrespect of the courts and its rules,” the SC said.

It added that the misrepresentation also prejudiced the client, whose case was adversely affected after the trial court expunged the pleadings.

The Court also noted that Hidalgo had previously been suspended for one year in an earlier administrative case, aggravating the severity of his offense.

Aside from disbarment, the SC imposed a ₱35,000 fine for willful disobedience after Hidalgo failed to comply with orders from the IBP to submit required pleadings.