A.C. No. 5474 - Jardin vs. Villar, Jr.

Complainant: Redentor S. Jardin, a building contractor and plaintiff in Civil Case No. 21480 filed in the Metropolitan Trial Court, Quezon City, seeking the collection of ₱105,744.80 for an alleged unpaid contract price in relation to repair work.
Respondent: Atty. Deogracias Villar, Jr., engaged as counsel by the complainant and later subject to a complaint for disbarment for his professional negligence.

The respondent was retained to represent the complainant in his collection case.
The central allegation was that the respondent failed to file the Formal Offer of Documentary Exhibits—an act mandated by the court—which resulted in the dismissal of the underlying civil case.

The trial court repeatedly granted extensions for the respondent to file the required exhibits.

First extension on February 26, 2001: A ten (10) day period was allotted to submit the formal offer.
Second extension on March 30, 2001: Another ten (10) day period was given after noting non-compliance during the hearing.

Despite these extensions and multiple reminders, the respondent failed to file the required documents.

On May 7, 2001, the trial court issued an Order dismissing the case for lack of apparent interest from the counsel as reflected in the failure to submit the exhibits.

The complainant, following the dismissal, terminated the respondent’s services as his counsel.
He further alleged that the respondent did not return the original documentary exhibits promptly, only releasing them after a heated confrontation with his wife.
The complainant then filed a verified Affidavit-Complaint for the disbarment of the respondent, outlining the sequence of events and the professional lapses observed.

The Integrated Bar of the Philippines (IBP) was tasked with investigating the complaint after the respondent failed to file his comment and answer in due course.
Investigating Commissioner Attorney Milagros V. San Juan, of the IBP Commission on Bar Discipline, found the respondent liable for negligence.
The IBP’s Report and Recommendation detailed that the respondent’s failure to submit the Formal Offer of Documentary Exhibits directly led to the dismissal of the complaint’s cause, thereby prejudicing the client’s interests.
The investigation underscored that the respondent’s inaction spanned three months and nine days—throughout which he failed to comply with the court’s directives.

Whether Atty. Deogracias Villar, Jr. neglected his professional duty by failing to file the required Formal Offer of Documentary Exhibits, despite multiple extensions.
Whether such inaction amounted to a breach of the ethical responsibilities imposed on lawyers under the Code of Professional Responsibility.

Whether the respondent’s failure to comply with court orders and his subsequent inaction constitutes grounds for disciplinary measures, including suspension or disbarment.
Whether his conduct, which led to the dismissal of a client’s case and undermined the client’s trust, is sufficiently serious to warrant a penalty.

Whether the respondent’s conduct reflects a broader disregard for the duty of diligence, competence, and fidelity that the legal profession demands.
The extent to which a lawyer's inexcusable negligence, as demonstrated by failure to timely file pleadings or documents, impacts the administration of justice and public trust in the legal profession.