A.C. No. 10553 - Celedonio vs. Estrabillo

The case involves a disbarment complaint filed by Filipinas O. Celedonio against Atty. Jaime F. Estrabillo, alleging violations of several provisions of the Code of Professional Responsibility (CPR), including Canon 1, Canon 9, Canon 10, Canon 15, Canon 17, and Canon 19.
The complaint arose from a criminal case of estafa filed by Alfrito D. Mah against Celedonio’s husband in 2006, where respondent served as legal counsel for Mah.
Complainant contended that she attempted to negotiate with Mah’s wife to have the case dropped, only to learn that the matter was already in the hands of Mah’s lawyer.

In subsequent meetings with respondent, both husband and wife of the complainant negotiated for a settlement and withdrawal of the criminal case.
Respondent advised executing a deed of sale on the family house and lot (TCT No. 502969-R) as collateral security for settling the alleged embezzlement, assuring the parties that the deed of sale was for security purposes only and would not be registered or annotated on the title.
The criminal case was later dismissed after these arrangements were made, bolstering the complainant’s confidence in the respondent’s guidance.

Later, when the complainant, being the sole provider for the family, decided to sell the property, she received a court summons for a complaint for specific performance with a prayer for a writ of preliminary injunction (WPI) and temporary restraining order (TRO).
It was discovered that the deed of sale executed on May 5, 2008, had been acted upon by the respondent who, contrary to prior assurances, requested the Register of Deeds of Pampanga to register and annotate the deed on November 27, 2008.
Upon confronting the respondent about the registration, the respondent advised further negotiations with his client, despite already having provided assurances that no such registration would occur.

Facing a deadline for filing a responsive pleading and an impending TRO hearing, the complainant sought further clarification from the respondent.
The respondent prepared and filed a Motion for Extension of Time (December 22, 2008) and an Urgent Motion to Postpone (January 8, 2009) on behalf of the complainant, allegedly drafted by his secretary.
Despite the respondent’s promise, the motions led the complainant to wrongly assume that the hearing was postponed; however, the hearing proceeded on January 9, 2009, with the respondent in attendance.
Further, the respondent filed a notice of lis pendens and adverse claim against the property at the Register of Deeds, and later filed a Motion to Declare Defendants in Default on February 4, 2009, which was granted by the court on February 27, 2009.
On March 31, 2009, the civil case was decided in favor of the respondent’s clients, a decision that ultimately became final and executory.

The Integrated Bar of the Philippines Commission on Bar Discipline (IBP-CBD) investigated the complaint; aside from the act of instructing his secretary to file motions for the complainant, no other allegations of deceit or misconduct could be substantiated.
On May 22, 2012, the IBP-CBD recommended the suspension of respondent Atty. Jaime F. Estrabillo from the practice of law for six (6) months.
The IBP Board of Governors, in Resolution No. XX-2013-187 dated March 20, 2013, adopted the recommendation with modifications and reprimanded the respondent for violations of Rule 15.03 and Canon 17 of the CPR.
Motions for reconsideration filed by both parties were denied in Resolution No. XXI-2014-116 on March 21, 2014.
This Court was subsequently called to render its verdict on the matter.

Whether respondent Atty. Jaime F. Estrabillo should be administratively disciplined for his conduct in representing conflicting interests in the civil case arising from the execution and subsequent registration of a deed of sale.

Does the respondent’s act of instructing his secretary to prepare motions on behalf of the complainant, while also acting as counsel for his own client in the same case, constitute a breach of his ethical and professional responsibilities?
Is there sufficient evidence to show that the respondent’s actions violated Rule 15.03 (prohibiting representation of conflicting interests without written consent) and Canon 17 (duty of fidelity to the client) of the CPR?
To what extent did the respondent’s actions contribute to the adverse outcome for the complainant, such as her loss of a hearing opportunity in the civil case?