Title
Advincula vs. Macabata
Case
A.C. No. 7204
Decision Date
Mar 7, 2007
Atty. Macabata reprimanded for inappropriate conduct with client; Supreme Court found actions distasteful but not grossly immoral, issuing a stern warning.

Case Digest (A.C. No. 7204)

Facts:

  • Complainant’s engagement of legal services
    • In early December 2004, Cynthia Advincula sought the legal advice of Atty. Ernesto M. Macabata regarding her unpaid collectibles from Queensway Travel and Tours.
    • On December 11, 2004, respondent sent a demand letter to the concerned parties (Annex “I”).
  • Alleged improper conduct during meetings
    • February 10, 2005 at Zensho Restaurant, Tomas Morato, Quezon City
      • After discussing the case over dinner, respondent drove complainant home.
      • As complainant alighted, he held her arm, kissed her on the cheek, embraced her tightly, and kissed her on the lips.
    • March 6, 2005 at Starbucks, West Avenue, Quezon City
      • After finalizing the draft complaint, respondent again offered complainant a ride.
      • Along Roosevelt Avenue (near Felipe St.), respondent allegedly stopped the car, forcefully held her face, kissed her lips, and touched her breast; complainant resisted and exited the vehicle.
  • Subsequent communications
    • Evening of March 6, 2005, complainant texted refusal to continue the case; respondent replied with repeated apologies, admissions of feeling, and pleas to continue seeing her.
    • On March 7, 2005, respondent sent further apology texts seeking forgiveness and promising to behave.
  • Respondent’s answer and defenses
    • Admitted providing legal services and meeting complainant on the specified dates.
    • Admitted kissing but maintained complainant offered her cheek and lips; denied force, breast holding, or lewd intent; stressed the public, busy location.
    • Raised defenses regarding complainant’s pending criminal complaint, marital status, and his payment of their meeting expenses.
  • IBP proceedings and recommendation
    • Hearing conducted by the IBP Commission on Bar Discipline on July 26, 2005.
    • Investigating Commissioner recommended one-month suspension (Report dated September 30, 2005).
    • IBP Resolution No. XVII-2006-117 (March 20, 2006) modified sanction to suspension for three months.

Issues:

  • Did Atty. Macabata commit grossly immoral acts or serious moral depravity warranting his disbarment or suspension?
  • If misconduct is established, what disciplinary sanction is appropriate?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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