Case Digest (A.C. No. 5019)
Facts:
In the case of Judge Adoracion G. Angeles vs. Atty. Thomas C. Uy Jr., the complainant, Judge Adoracion G. Angeles, filed a complaint against Atty. Thomas C. Uy Jr. on February 11, 1999, alleging a violation of Canon 16 of the Code of Professional Responsibility. The events leading to this complaint occurred during a hearing on February 10, 1999, in the Regional Trial Court of Caloocan City, where Atty. Uy was acting as the private prosecutor in a criminal case against Norma Trajano. During the proceedings, it was revealed that Trajano had settled the civil aspect of the case by paying a total of P36,500.00, of which P20,000.00 was paid directly to the private complainant, Primitiva Malansing Del Rosario, while the remaining P16,500.00 was given to Atty. Uy. However, Del Rosario claimed she had not received the latter amount, prompting Judge Angeles to order Atty. Uy to turn over the money to her. Atty. Uy argued that Del Rosario did not want to accept the money, a claim that ...
Case Digest (A.C. No. 5019)
Facts:
- Background of the Case: Judge Adoracion G. Angeles of the Regional Trial Court of Caloocan City filed an administrative complaint against Atty. Thomas C. Uy Jr. for violating Canon 16 of the Code of Professional Responsibility.
- Incident in Court: During a hearing on February 10, 1999, accused Norma Trajano revealed that she had fully settled the civil aspect of the case, paying P20,000 directly to the private complainant, Primitiva Del Rosario, and P16,500 to Atty. Uy.
- Failure to Deliver Funds: Primitiva Del Rosario stated in court that she had not received the P16,500 paid to Atty. Uy. The court directed Atty. Uy to turn over the money, but he failed to comply, claiming the money was in his office.
- Disobedience of Court Order: Atty. Uy did not return to court after being given time to retrieve the money, leading Judge Angeles to conclude that he had disobeyed a court order and mocked the court’s authority.
Issue:
- Professional Misconduct: Whether Atty. Uy violated Canon 16 of the Code of Professional Responsibility by failing to promptly account for and deliver funds received on behalf of his client.
- Disobedience of Court Order: Whether Atty. Uy’s failure to comply with the court’s directive to turn over the money constituted disobedience and disrespect for the court.
Ruling:
The Supreme Court found Atty. Thomas C. Uy Jr. guilty of professional misconduct for failing to promptly account for and deliver the P16,500 received on behalf of his client, Primitiva Del Rosario. He was suspended from the practice of law for one month.
Ratio:
- Fiduciary Duty of Lawyers: Lawyers hold a fiduciary relationship with their clients and are required to promptly account for and deliver any money or property received on their behalf.
- Violation of Canon 16: Atty. Uy’s failure to immediately remit the P16,500 to his client and his delay in accounting for the funds violated Canon 16 and Rule 16.01 of the Code of Professional Responsibility.
- Discrediting the Legal Profession: By keeping the money without his client’s knowledge and failing to comply with the court’s order, Atty. Uy undermined the integrity of the legal profession and betrayed the trust reposed in him as an officer of the court.
- Sanction: While there was no clear evidence of misappropriation, Atty. Uy’s failure to promptly report and deliver the funds warranted a one-month suspension from the practice of law.