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Manubay vs Garcia

RICARDO B. MANUBAY, complainant, vs. Atty. GINA C. GARCIA, respondent.

A.C. No. 4700 | 2000-04-12

D E C I S I O N


PANGANIBAN, J.:

In administrative cases against lawyers, the burden of proof rests upon the complainant. Administrative complaints that are prima facie groundless as shown by the pleadings filed by the parties need not be referred to the Integrated Bar of the Philippines for further investigation. They may be summarily dismissed for utter lack of merit.



The Case and the Facts



In a verified Complaint dated February 5, 1997 and addressed to the Office of the Bar Confidant, Ricardo B. Manubay charged Atty. Gina C. Garcia with misconduct in the performance of her duties as a notary public. The Complaint reads as...