A.M. No. 1053 – 93 SCRA 87 – Legal Ethics – Lack of Candor by a Lawyer – Proper name to be used by a lawyer; Lawyer must use real name
In 1979, a pending administrative case filed by Santa Pangan against Atty. Dionisio Ramos was delayed because Atty. Ramos allegedly appeared before a court in Manila. When the records of the said case was checked (one which Atty. Ramos appeared in), it was found that he used the name “Atty. Pedro D.D. Ramos”. In his defense, Atty. Ramos said he has the right to use such name because in his birth certificate, his name listed was Pedro Dionisio Ramos. “D.D.” stands for Dionisio Dayaw with Dayaw being his mother’s surname. However, in the Roll of Attorneys, his name listed was Dionisio D. Ramos.
ISSUE: Whether or not what Atty. Ramos did was correct.
HELD: No. The attorney’s roll or register is the official record containing the names and signatures of those who are authorized to practice law. A lawyer is not authorized to use a name other than the one inscribed in the Roll of Attorneys in his practice of law. The official oath obliges the attorney solemnly to swear that he will do no falsehood. As an officer in the temple of justice, an attorney has irrefragable obligations of truthfulness, candor and frankness. In representing himself to the court as “Pedro D.D. Ramos” instead of “Dionisio D. Ramos”, he has violated his solemn oath and has resorted to deception. The Supreme Court hence severely reprimanded Atty. Ramos and warned that a similar infraction will warrant suspension or disbarment.