A.C. No. 3967 - Endaya vs. Oca

On November 7, 1991, a complaint for unlawful detainer (Civil Case No. 34-MCTC-T) was filed by Apolonia H. Hornilla, Pedro Hernandez, Santiago Hernandez, and Dominador Hernandez against Artemio Endaya and his spouse, Patrosenia Endaya.
On December 13, 1991, the complainant and his wife filed their answer, which was prepared by a non-designated lawyer, Mr. Isaias Ramirez.
A preliminary conference was held on January 17, 1992, which the complainant attended without legal counsel, during which he admitted that the plaintiffs were the declared owners for taxation purposes of the subject property.

At the continuation of the preliminary conference on January 31, 1992, the complainant engaged the services of the Public Attorney’s Office in Batangas City where respondent Atty. Wilfredo Oca was assigned.
The respondent appeared as counsel and moved for the amendment of the answer previously filed; however, his motion was denied by the court.
The Municipal Circuit Trial Court (MCTC) presided by Acting Trial Court Judge Teodoro M. Baral ordered the parties to submit their affidavits and position papers within ten days, and scheduled judgment thirty days thereafter.

Respondent failed to submit the required affidavits and position papers, as only the plaintiffs complied, leading the MCTC to dismiss the unlawful detainer complaint on the ground that the plaintiffs were not the real parties-in-interest and lacked privity of contract regarding the verbal lease agreement.
After the MCTC’s decision dated March 19, 1992, the plaintiffs appealed the case to the Regional Trial Court (RTC) of Batangas City, Branch 1 (Civil Case No. 3378).
The RTC, after directing the parties to file their respective memoranda on April 10, 1992, noted once again that the respondent failed to file a memorandum for his clients, and consequently, rendered judgment reversing the MCTC decision—upholding the plaintiffs' title and ordering the defendants to vacate the property with associated penalties.

The complainant received a copy of the RTC decision on October 7, 1992, and confronted the respondent on October 9, 1992, who denied receiving a copy, although records showed he had received it earlier.
On January 12, 1993, following the loss of the unlawful detainer case, the complainant filed an administrative complaint against Atty. Wilfredo Oca alleging professional delinquency or infidelity and violation of the lawyer’s oath caused by the failure to file necessary pleadings.
In a Comment dated March 17, 1993, the respondent claimed that his involvement had been limited to seeking leave to file an amended answer after being misled about the preparation of the original answer and that he had attempted to extricate himself from the case when his client reneged on providing supporting documents.
The case proceeded with additional orders requiring respondent to file a rejoinder to the complainant’s reply (as directed on July 28, 1993), which respondent failed to submit even after prolonged delay.
Consequently, the matter was referred to the Office of the Bar Confidant (June 16, 1997) and later to the Integrated Bar of the Philippines (IBP) for investigation, with the final reports finding respondent negligent and recommending disciplinary measures.

Whether respondent’s failure to file the required affidavits, position papers, appeal memorandum, and subsequent rejoinder constitutes professional negligence.
Whether such inaction deprived the client of the opportunity to adequately present and defend his case.

Whether the respondent’s conduct breached the fundamental duties under the lawyer’s oath and the Code of Professional Responsibility, specifically regarding diligence, competence, and fidelity to the client’s cause.
Whether his actions exhibited a disregard for court orders and the administrative rules governing pleadings, thus undermining the administration of justice.

Whether the respondent, as a lawyer employed by the Public Attorney’s Office, failed extra duties imposed on government lawyers to provide competent and diligent legal assistance.
Whether his conduct, marked by indifference and delay, compromised public trust and the effective delivery of legal services to indigents and low-income clients.