Title
Barrientos vs. Libiran-Meteoro
Case
A.C. No. 6408
Decision Date
Aug 31, 2004
Atty. Libiran-Meteoro suspended for 6 months for issuing bounced checks and failing to pay debts, violating professional ethics; ordered to repay P84,000.
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Case Digest (A.C. No. 6408)

Facts:

Background of the Complaint

  • Isidra Barrientos filed a complaint for disbarment against Atty. Elerizza A. Libiran-Meteoro for deceit and non-payment of debts.
  • The complaint was filed with the Integrated Bar of the Philippines (IBP) on May 21, 2001, under the names of Isidra Barrientos and Olivia C. Mercado, but only Isidra signed it.

Issuance of Bounced Checks

  • In September 2000, Atty. Libiran-Meteoro issued several Equitable PCIBank checks in favor of Isidra and Olivia, amounting to P67,000.00, and in favor of Olivia, totaling P234,000.00, to pay a pre-existing debt.
  • The checks bounced due to insufficient funds, leading to the filing of criminal charges for violation of B.P. 22 (Bouncing Checks Law) with the City Prosecutor of Cabanatuan.

Attempts to Settle the Debt

  • Atty. Libiran-Meteoro sent text messages to the complainants, asking for the deferment of the criminal charges and promising to pay her debt. However, she failed to fulfill this promise.
  • On May 16, 2001, Atty. Libiran-Meteoro, through her sister-in-law, attempted to give the complainants a title for a parcel of land in exchange for the bounced checks. The land, located in Bantug, La Torre, Talavera, Nueva Ecija, was registered in the name of Victoria Villamar.
  • Upon checking, the complainants discovered that the land belonged to Dra. Helen Garcia, the sole heir of Victoria Villamar, who had merely entrusted the title to Atty. Libiran-Meteoro for a transaction with Quedancor.

Respondent's Defense

  • In her Answer, Atty. Libiran-Meteoro denied issuing checks to Isidra, claiming that the checks were issued only to Olivia. She also stated that the checks had been replaced and that the criminal case had been dismissed.
  • She attached an affidavit from Olivia C. Mercado, who stated that the complaint was filed due to a misunderstanding and that she had no cause of action against Atty. Libiran-Meteoro.

Proceedings Before the IBP

  • The IBP-Commission on Bar Discipline (CBD) held several hearings, during which Atty. Libiran-Meteoro acknowledged her indebtedness to Isidra in the amount of P134,000.00 and agreed to pay in staggered installments.
  • Despite this agreement, Atty. Libiran-Meteoro failed to appear in subsequent hearings and did not fully settle her debt.

Findings of the IBP-CBD

  • The Investigating Commissioner found that Atty. Libiran-Meteoro had violated the Code of Professional Responsibility, particularly Canon 1 and Rule 1.01, which require lawyers to maintain good moral character and honesty.
  • The Commissioner recommended a two-year suspension from the practice of law and a fine of P20,000.00.

IBP Board of Governors' Resolution

  • The IBP Board of Governors modified the recommendation, suspending Atty. Libiran-Meteoro from the practice of law for six months and ordering her to pay the balance of P84,000.00 to Isidra Barrientos.

Issue:

  1. Whether Atty. Elerizza A. Libiran-Meteoro violated the Code of Professional Responsibility by failing to pay her debts and issuing worthless checks.
  2. Whether Atty. Libiran-Meteoro should be held liable for attempting to negotiate a transfer certificate of title that was not hers.
  3. Whether the recommended sanctions by the IBP are appropriate.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

  • Atty. Elerizza A. Libiran-Meteoro was suspended from the practice of law for six months and ordered to pay the balance of her debt to Isidra Barrientos. The Court emphasized that lawyers must uphold the integrity of the legal profession by adhering to ethical standards and promptly fulfilling their financial obligations.


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