Title
Ledesma vs. Climaco
Case
G.R. No. L-23815
Decision Date
Jun 28, 1974
Election Registrar Ledesma sought to withdraw as court-appointed counsel due to his new role, but the court denied his motion, emphasizing lawyers' duty to serve as counsel de oficio without grave abuse of discretion.

Case Digest (G.R. No. L-23815)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Petitioner Adelino H. Ledesma was originally retained as counsel de parte for two accused in a criminal case before Branch I of the CFI of Negros Occidental, Silay City.
    • Respondent Hon. Rafael C. Climaco is the Presiding Judge of that court.
  • Chronology of Events
    • October 13, 1964 – Petitioner appointed Election Registrar for Cadiz, Negros Occidental by the Commission on Elections and commenced duties.
    • October 15–16, 1964 – Petitioner moved for postponement of the trial; respondent Judge denied postponement but designated him counsel de oficio to avoid prejudice to his civil service status.
    • November 3, 1964 – Petitioner filed an “urgent motion to withdraw” as counsel de oficio, alleging full-time duties as Election Registrar and potential conflict with trial responsibilities.
    • November 6, 1964 – Respondent Judge denied petitioner’s motion to withdraw; motion for reconsideration likewise denied.
    • Petitioner then filed a petition for certiorari alleging grave abuse of discretion by the respondent Judge in refusing his withdrawal.

Issues:

  • Whether the respondent Judge’s denial of petitioner’s motion to withdraw as counsel de oficio constitutes a grave abuse of discretion.
  • Whether petitioner’s appointment as Election Registrar and alleged workload justified his withdrawal from representation as court-appointed counsel.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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