A.C. No. 7136 - Guevarra vs. Eala

The case involves Atty. Roy Prule Ediza, who was previously found administratively liable for violating provisions of the Code of Professional Responsibility concerning dishonesty and misconduct.
The administrative liability stemmed from a Complaint/Affidavit dated 8 September 2000 filed by Nemesio Floran and Caridad Floran, the complainants.
The subject matter was a 3.5525-hectare parcel of unregistered land in San Martin, Villanueva, Misamis Oriental, initially covered by a tax declaration in the name of Sartiga Epal.

Atty. Ediza is accused of deceiving the complainants by having them unknowingly sign a deed of sale that transferred a portion of their land to him.
He misappropriated half of the proceeds from the sale, falsely assuring the complainants that he would register the remaining portion of the property using the same proceeds.
His acts were deemed deceitful and unworthy of a member of the legal profession, displaying conduct that violated Rule 1.01 of Canon 1, Canon 15, and Rule 18.03 of Canon 18 of the Code of Professional Responsibility.

Atty. Ediza was suspended from the practice of law for six months.
He was directed to return to the complainants two sets of documents that were procured through misrepresentation (signed by both the complainants and Sartiga Epal).
He was ordered to pay the complainants the amount of P125,463.38 plus legal interest from 8 September 2000 until full payment.

Atty. Ediza filed a Motion for Reconsideration on 18 November 2011, which was denied on 8 February 2012 due to lack of substantial merit.
He submitted a Manifestation of Compliance regarding the suspension order on 29 May 2012 along with a sworn statement that he had desisted from the practice of law during the suspension period.
A Resolution dated 3 September 2012 required:

Submission of certifications from the IBP Local Chapter and the Office of the Executive Judge to confirm his suspension period.
Proof of payment to the complainants and the return of the contested documents.

Complainants made several manifestations via letters (undated vernacular letters, one on 17 October 2012, and subsequent letters in February 2014 and July 2014) indicating that Atty. Ediza had not yet complied with the court’s orders.

Despite repeated resolutions (dated 25 February 2013, 15 July 2013, 4 June 2014, and 12 November 2014) from the Court requiring compliance:

Atty. Ediza failed to submit the necessary certifications guaranteeing his suspension.
He did not pay the required sum or return the contested documents.

He had no intention to defy the Court’s authority.
The documents mentioned in the original order were either ambiguous or fictitious.
New evidence suggested that the complainants might have engaged in fraudulent schemes.
The administrative proceedings were complained of as lacking due process.

He further filed motions (including a Compliance with a Motion to Reopen/Reinvestigate on 2 August 2014 and another on 7 February 2015) requesting stays on the execution of the decision and other reliefs.
Throughout the proceedings, his actions were characterized by blatant disregard and resistance to the Court’s directives.

More than four years had elapsed since the initial 19 October 2011 Decision, yet Atty. Ediza remained non-compliant with its mandates.
The Court noted his persistent defiance despite multiple warnings and orders, deeming his conduct as disrespectful to the Court and indicative of grave misconduct.
The cumulative record revealed that his continued behavior constituted willful disobedience and a flagrant disregard for the orderly administration of justice.

Whether Atty. Ediza’s misconduct, repetition of deceptive practices, and failure to comply with multiple court orders constitute grounds for severe disciplinary measures, including disbarment.
Whether his continuous non-compliance with the Court’s directives, despite prior suspension and warnings, demonstrates an irreparable disregard of judicial authority.
Whether the newly raised arguments and alleged ambiguity regarding the documents can excuse his repeated failure to perform the mandated obligations.
Whether Atty. Ediza’s conduct, including the claim of newly discovered evidence and assertions of due process violations, undermines the integrity and authority of the Court’s established disciplinary procedures.