Facts:

The case involves Atty. Claro Jordan M. Santamaria as the respondent and the spouses Bayani and Myrna M. Partoza as the complainants. The events leading to this administrative case began with a civil action filed by the spouses Partoza against Lilia B. Montano and Amelia T. Solomon for the Declaration of Nullity of a Deed of Real Estate Mortgage, Reconveyance of Transfer Certificate of Title No. T-710729, and Damages. The Regional Trial Court dismissed the case on October 28, 2010. Subsequently, on November 25, 2010, Atty. Samson D. Villanueva, the counsel on record for the spouses Partoza, filed a Notice of Appeal, which was docketed as CA G.R. CV No. 96282. The Court of Appeals (CA) required the submission of the Appellant's Brief in a Notice dated March 25, 2011. However, on April 27, 2011, Atty. Villanueva filed a Withdrawal of Appearance, which was acknowledged by Honnie M. Partoza, the attorney-in-fact for the appellants. Following this, Atty. Santamaria submitted a...

Facts:

Background of the Case

• A civil action for the declaration of nullity of a deed of real estate mortgage, reconveyance of Transfer Certificate of Title No. T-710729, and damages was instituted by the spouses Bayani and Myrna M. Partoza against Lilia B. Montano and Amelia T. Solomon.
• The Regional Trial Court dismissed the case, prompting the filing of a Notice of Appeal.

Procedural History and Representation

• On November 25, 2010, Atty. Samson D. Villanueva filed the Notice of Appeal on behalf of the appellants.
• In a subsequent development, Atty. Villanueva filed his Withdrawal of Appearance, which had the conformity of the appellants’ attorney-in-fact, Honnie M. Partoza, who also acknowledged receipt of the case records.
• Following the withdrawal, respondent Atty. Claro Jordan M. Santamaria submitted an Appellant’s Brief on July 4, 2011, seemingly assuming the role for the appellants without proper substitution procedures.

Court of Appeals’ Directives and Noncompliance

• The CA, in its Resolution dated August 4, 2011, directed:
• Atty. Villanueva to provide proof that Honnie M. Partoza was duly authorized to represent the appellants and that she conformed with his withdrawal.
• The respondent to file a formal Entry of Appearance as counsel for the appellants and to submit the requisite documents for a valid substitution.
• Atty. Villanueva later filed a Manifestation with Motion on August 31, 2011, explaining that he had been informed that the appellants were residing abroad, and requested a 15-day period to comply with the CA’s directive.
• The CA issued further resolutions:
• On March 20, 2012, ordering Atty. Villanueva to show cause why he should not be cited in contempt for noncompliance and why the Appellant’s Brief should not be expunged.
• On September 5, 2012, reiterating the need for compliance by directing the respondent to meet the requirements within five days and warning of contempt.
• On October 25, 2012, citing the respondent in contempt of court and imposing a fine of ₱5,000.00 for his failure to remit any compliance.
• Ultimately, in a Resolution dated April 11, 2013, the CA ordered the expungement of the respondent’s Appellant’s Brief, dismissed the appeal, and directed him to explain why he should not be suspended from the practice of law.

IBP Investigation and Administrative Sanction

• The CA referred the respondent’s alleged “lawyerly” misconduct to the Integrated Bar of the Philippines (IBP) for investigation, report, and recommendation.
• In his November 13, 2013 Answer, the respondent claimed:
• That he had been engaged after the spouses sought his legal opinion and subsequent representation.
• That he relied on Atty. Villanueva’s withdrawal and was not aware of the full scope of the substitution requirements, including Honnie’s authority.
• That he believed Atty. Villanueva should have continued to represent the appellants.
• The Investigating Commissioner, Michael G. Fabunan, found the respondent liable for willful disobedience of the CA’s lawful orders and recommended his suspension from the practice of law for six months.
• The IBP Board of Governors adopted this recommendation, and no petition for review or motion for reconsideration was filed.

Final Disciplinary Action

• The Supreme Court adopted the findings of fact and penalty recommended by the IBP.
• The Court emphasized the lawyer’s duty to obey lawful court orders and the grave consequences of repeated noncompliance.
• As a result, respondent Atty. Claro Jordan M. Santamaria was suspended from the practice of law for six months, with stern warnings of harsher penalties for any repetition of similar misconduct.

Issue:

Whether respondent Atty. Claro Jordan M. Santamaria is administratively liable for his willful and repeated disobedience of the CA’s directives.

• Does the respondent’s failure to comply with multiple CA resolutions constitute contempt of court?
• Is the respondent’s conduct sufficient to warrant not only contempt sanctions but also a suspension from the practice of law?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)