Facts:

The case involves a disbarment complaint against Atty. Clemencio Sabitsana, Jr., filed by complainant Josefina M. Aniaon. This matter arose from events surrounding the preparation and execution of a Deed of Sale for a parcel of land owned by Aniaon's late common-law husband, Brigido Caneja, Jr. On April 11, 2012, the Supreme Court of the Philippines rendered its decision regarding the case, which had progressed through the Integrated Bar of the Philippines (IBP) and involved prior investigation resolutions. Aniaon alleged that Atty. Sabitsana breached his duty by utilizing confidential information gathered during their attorney-client relationship when he represented Zenaida L. CaAete, Caneja’s legal wife, in a civil action to annul the Deed of Sale. Atty. Sabitsana countered by denying any receipt of confidential information and asserting that the complaint against him was motivated by a prior dispute with another attorney, Atty. Gabino Vel

Facts:

In this case, Complainant Josefina M. Aniaon filed a disbarment complaint against Atty. Clemencio Sabitsana, Jr. alleging that the latter violated his duty to preserve client confidentiality and represented conflicting interests. Specifically, Atty. Sabitsana had previously been engaged by the complainant to prepare and execute a Deed of Sale for a parcel of land belonging to her late common-law husband. Subsequently, he represented Zenaida L. Canaete—the legal wife of her late partner—in a civil case seeking annulment of the very same Deed of Sale. The complainant asserted that by accepting the new engagement and filing the civil case on behalf of Zenaida Canaete, Atty. Sabitsana not only used information that was confidentially conveyed by her but also directly pitted his client’s interests against those of another client. Although Atty. Sabitsana admitted to having advised the complainant during the preparation of the Deed of Sale, he denied ever receiving confidential information and claimed that the complaint was instigated by a rival lawyer. Prior to coming before the Court, the Integrated Bar of the Philippines (IBP) conducted an investigation and found him administratively liable for representing conflicting interests. The IBP Commissioner and subsequently the IBP Board of Governors both recommended sanctions, ultimately proposing a one-year suspension from the practice of law.

Issue:

The primary issue in this case is whether Atty. Sabitsana committed professional misconduct by representing conflicting interests—specifically, whether his simultaneous engagements for two parties with directly opposing claims to the same property violated the ethical rules governing the legal profession. A secondary issue raised is whether the failure to secure written consent from both clients, after full disclosure of the pertinent facts, compounded his misconduct.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)