REPUBLIC OF THE PHILIPPINES Office of the Bar Confidant SUPREME COURT En Banc MANILA

_______________________, Complainant, -versusAtty. Juan Tamad, Respondent. X-------------------------------X A.C. NO.______________ For: Disbarment

VERIFIED DISBARMENT COMPLAINT / LETTER-AFFIDAVIT (For violation of Canon 2.03 and 1.03 of the Canon of Professional Responsibility and Section 27, Rule 138 of the Rules of Court) Chief Justice __________________, and the MEMBERS, En Banc, SUPREME COURT, Padre Faura, Manila Your Honors, I, the undersigned petitioner,________________, under oath, by myself and for myself, as a litigant / complainant in this case, most respectfullt depose and say, that: 1. City. Complainant is of legal age, single, Filipino Citizen,

and a resident of RM. 405, Keppel Bldg., Cebu Business Park, Cebu

2.

Respondent is a member of the bar and a resident of

2/F, Quest Hotel and Residences, Lahug, Cebu City. 3. Respondent, with the help of paralegal Maria,

convinced his clients to transfer legal representation. 4. Respondent promised them financial assistance and

expeditious collection of their claims. 5. To induce them to hire his services, he persistently

called them and sent them text messages. 6. Respondent tried to prevail upon the complainant to

sever his lawyer-client relations with complainant in exchange for a loan of P 200,000.00. 7. respondent as well gave his calling card to the

complainant. Attached and marked as annex A is the calling card given by the respondent. RELIEF In light of the foregoing, it is respectfully prayed that the instant violation VERIFIED of Canon and DISBARMENT 2.03 Section and 27, COMPLAINT 1.03 Rule of 138 / the of LETTER-AFFIDAVIT Canon the of Rules of (For Court) Professional

Responsibility

against respondent, Atty. Juan Tamad, be duly noted, admitted, given due course and granted. Further, it is respectfully prayed, that judgment be rendered declaring him guilty and supreme penalty of disbarment be imposed upon him, ordering that his name be stricken from the Roll of Attorneys, and punished accordingly.

Other

legal

and

equitable

reliefs

as

may

be

applicable

are

likewise prayed for. IN WITNESS WHEREOF, I signed this pleading letter-affidavitcomplaint, this 1st day of august, 2012, at Cebu City.

ATTY ._________________ Petitioner, on behalf of the ____ as litigant, 123 St., ABC Village, Ma. Luisa, Banilad, Cebu City MCLE Compliance No. PTR No. IBP No.

NOTICE TO: ATTY._____________ The Office of the Bar Confidant ATTY .___________________ The Clerk of Court, Supreme Court, Manila

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING I, _______________________, of legal age, after having been duly sworn in accordance with law, depose and state that: 1. I am a plaintiff in the above-stated case; 2. I caused the preparation of the foregoing complaint; 3. I have read the contents thereof and the facts stated therein are true and correct of my personal knowledge and/or on the basis of copies of documents and records in my possession; 4. I have not commenced any other action or proceeding involving the same issues in the Supreme Court, the Court of Appeals, or any other tribunal or agency; 5. To the best of my knowledge and belief, no such action or proceeding is pending in the Supreme Court, the Court of Appeals, or any other tribunal or agency; 6. If I should thereafter learn that a similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or any other tribunal or agency, I undertake to report that fact within five (5) days therefrom to this Honorable Court. ___________________________ Affiant SUBSCRIBED AND SWORN to before me this ___ day of __________ 200_ at _________________ affiant exhibiting to me his Community Tax Certificate No.____________________ issued on ________________ 200_ at ______________ City. Doc. No. ; Page No. ; Book No. ; Series of 2012.

PEDRO PINDOKO Notary Public until Jan.31, 2013 PTR No. IBP No. COPY FURNISHED: ATTY. JUAN TAMAD 2/F, Quest Hotel and Residences, Lahug, Cebu City