Facts:

The case involves an administrative complaint filed by Isaac C. Basilio, Perlita Pedrozo, and Jun Basilio against Atty. Virgil R. Castro. The events leading to the complaint began on July 5, 2004, when the complainants engaged Atty. Castro to represent them in three civil cases: Civil Case Nos. 1427 and 1428 before the Municipal Trial Court (MTC) of Bambang, Nueva Vizcaya, and Civil Case No. 883 with the Regional Trial Court (RTC) of Bayombong, Branch 37. The cases before the MTC were for forcible entry against the complainants, while the RTC case was for quieting of title. On February 10, 2005, the MTC ruled against the complainants, and their subsequent appeal was dismissed by RTC Branch 30 due to their failure to file the required appellants' memorandum. At the time of the administrative complaint, the RTC case was still pending. The complainants alleged that they paid Atty. Castro a total of P60,000 as acceptance and filing fees, despite the actual filing fee being on...

Facts:

Engagement of Legal Services

• On 5 July 2004, complainants Isaac C. Basilio, Perlita Pedrozo, and Jun Basilio engaged the legal services of Atty. Virgil R. Castro to handle three civil cases:
  1. Civil Case Nos. 1427 and 1428 before the Municipal Trial Court (MTC) of Bambang, Nueva Vizcaya, which were forcible entry cases filed against the complainants.
  2. Civil Case No. 883 before the Regional Trial Court (RTC) of Bambang, Nueva Vizcaya, Branch 37, which was a quieting of title case filed by the complainants.

Outcome of the Cases

• On 10 February 2005, the MTC ruled against the complainants in Civil Case Nos. 1427 and 1428. They appealed the decision, but the appeal was dismissed by the RTC, Branch 30, due to their failure to file the required appellant's memorandum despite notice.
• Civil Case No. 883 was still pending at the time the administrative complaint was filed.

Complainants' Allegations

• Complainants alleged that they paid Atty. Castro:
  • P40,000 as an acceptance fee.
  • P20,000 as a filing fee, despite the actual filing fee being only P1,000.
• They also claimed that Atty. Castro failed to prosecute the cases before the MTC, resulting in their dismissal.

Atty. Castro's Defense

• Atty. Castro clarified that he was preceded by two other lawyers in the cases and that he exerted efforts to protect his clients' interests.
• He claimed that the complainants instructed him to abandon the appeal due to their inability to file the required supersedeas bond.
• He also stated that he used the money received from the complainants to pay for legal fees and filing fees for the appeal.

Proceedings Before the IBP

• The case was referred to the Integrated Bar of the Philippines (IBP) for investigation.
• No actual hearing took place due to various reasons, including the absence of parties and the Investigating Commissioner.
• The parties submitted Pre-trial Briefs, with complainants alleging that they paid Atty. Castro a total of P110,500, of which only P40,000 was receipted.

IBP Findings

• The Investigating Commissioner found insufficient evidence to prove that Atty. Castro reneged on his obligations in Civil Case No. 883.
• However, Atty. Castro was held administratively liable for failing to file the appellant's memorandum in the appeal before RTC Branch 30.
• The IBP Board of Governors recommended a three-month suspension for Atty. Castro.

---

Issue:

• Whether Atty. Virgil R. Castro should be held administratively liable for his failure to file the mandatory appellant's memorandum before RTC Branch 30.

---

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)