Facts:

The case involves Flora Baguisa and Rufino Baguisa as complainants against Alejandro A. de Guzman, who was admitted to the practice of law on January 21, 1955. The administrative complaint was filed on two counts: (1) gross negligence in the performance of his duties as a lawyer for the Baguisas, and (2) betrayal of confidential communications made to him by them as clients. The events leading to the complaint began in May 1961 when the Baguisas requested de Guzman to prepare a deed of sale for a bulldozer, which was to be signed by Jacinto Matias and his wife in favor of the Baguisas. The complainants alleged that de Guzman failed to prepare this document, which they claimed was necessary to formalize their verbal agreement regarding the sale. De Guzman, however, denied ever receiving such a request.

On June 9, 1961, the Baguisas executed an option sale for the bulldozer in favor of Gloria Gener. Subsequently, on June 12, 1961, they granted de Guzman a special power of at...

Facts:

Parties and Charges

• Complainants: Flora Baguisa and Rufino Baguisa.
• Respondent: Alejandro A. de Guzman, an attorney admitted to practice on January 21, 1955.
• Charges:
• Gross negligence in the performance of his duties as the Baguisas’ legal representative.
• Betrayal of confidential communications between him and the Baguisas.

Chronological Background and Transaction Details

• May 1961
• The Baguisas allegedly requested de Guzman to prepare a deed of sale for a bulldozer; de Guzman denied any such request.
• June 9, 1961
• An option sale covering the same bulldozer was executed by the Baguisas in favor of Gloria Gener.
• June 12, 1961
• The Baguisas executed a special power of attorney in favor of de Guzman.
• The instrument authorized him to negotiate with Gloria Gener—or any other party—for the final sale of the bulldozer.
• June 13, 1961
• Acting as their agent, de Guzman executed a deed of sale to Gloria Gener.
• Terms of the deed of sale:
• Purchase price: P18,000.
• Down payment: P6,125.
• Balance payable in installments over six months, secured by a chattel mortgage in favor of the Baguisas.

Subsequent Legal and Factual Developments

• The Baguisas later initiated:
• A civil action in the Court of First Instance of Nueva Ecija against Loreto Sta. Ines and Jacinto Matias to enforce the execution of a formal deed of sale for the bulldozer.
• A replevin suit in Quezon City against Gloria Gener to recover possession of the bulldozer.
• Jacinto Matias filed a criminal complaint for estafa against the Baguisas and de Guzman.
• On March 7, 1963
• De Guzman moved the City Fiscal to drop the estafa charges against him.
• He asserted that his actions were in strict accordance with the special power of attorney.
• He further testified that the Baguisas had assured him that the bulldozer belonged to them and that a court suit had already been instituted by them against Gloria Gener for non-payment.

Nature of the Fee and Engagement

• The Baguisas claimed they paid de Guzman P600 for "legal services."
• De Guzman admitted receiving only P400, which he characterized as reimbursement for expenses and compensation for his agency services.
• In subsequent civil cases, the Baguisas employed the services of another lawyer, suggesting no formal and continuous attorney-client engagement.

Evidentiary Discrepancies and the Administrative Complaint

• There are conflicting declarations:
• The Baguisas allege de Guzman’s negligence in not preparing the deed of sale in proper form.
• De Guzman maintained that no such request was made and that his actions were confined to the authority given by the special power of attorney.
• Testimony from Flora Baguisa indicated that the deed of sale was contingent upon the completion of payment by Mrs. Gener and was not expected in May 1961.
• The record and other circumstances cast doubt on whether de Guzman’s conduct amounted to either gross negligence or breach of confidential communications.

Issue:

• Did de Guzman, as an agent under a special power of attorney, negligently fail to prepare the deed of sale that would have solidified the contractual obligations for the bulldozer transfer?
• Does de Guzman’s filing of the motion to dismiss the estafa charges with the City Fiscal constitute a betrayal of confidential communications or a breach of duty?
• Was the engagement between the Baguisas and de Guzman intended to be a full attorney-client relationship or merely an agency relationship as evidenced by the limited scope of the special power of attorney?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)