G.R. No. 132577 - People vs. Webb

On September 26, 2011, the Court issued a decision suspending respondent, Atty. Macario D. Carpio, from the practice of law for six (6) months.
The same decision ordered respondent to return the owner’s duplicate of OCT No. 0-94 to complainant, Valentin C. Miranda, immediately upon receipt of the decision.
The order explicitly warned that any repetition of the same or similar acts would result in a more severe sanction.
On July 28, 2014, the Court, in a follow-up resolution, required respondent to show cause why he should not be held in contempt for failing to comply with its prior order.
The Court further directed respondent to file a sworn statement with motion to lift his suspension, accompanied by certifications from his IBP Local Chapter and the Office of the Executive Judge of the courts where he practices, confirming that he had served his suspension (from October 12, 2011 to April 12, 2012).

In a letter dated August 21, 2014, respondent attached a previous letter (dated May 25, 2014) asserting that he was ready to return the owner’s duplicate of OCT No. 0-94.
He argued that the complainant, not he, had failed to personally claim the title, and that due to security concerns, he could only release the document to the complainant.
Respondent cited his advanced age as a factor rendering him incapable of personally delivering the document.
In his Explanation/Compliance/Motion to Lift Order of Suspension dated October 28, 2014, respondent contended that he received the duplicate as proof of his success in handling LRC Case No. M-226, not from the complainant.
He reiterated that the complainant had not claimed the document and further argued that his acceptance of a new case—despite his suspension—was driven solely by financial necessity and a mistaken belief that the suspension was automatically lifted after the prescribed period.

The Office of the Bar Confidant (OBC) recommended the denial of respondent’s motion to lift the suspension order.
The OBC further recommended that a harsher penalty be imposed due to his continuing non-compliance with the Court’s decision of September 26, 2011.
After reviewing the case records and the OBC’s recommendation, the Court adopted the OBC’s position.
The Court denied the motion to lift the suspension and imposed an additional six (6) months suspension on respondent, effective upon receipt of the resolution.
The Court also directed respondent to return the owner’s duplicate of OCT No. 0-94 to the complainant and warned that any repetition of such behavior would incur more severe sanctions.

Whether respondent’s justification that complainant’s failure to personally claim the owner’s duplicate of OCT No. 0-94 absolved him from the obligation to return it.
Whether respondent’s claims—including his advanced age, his assertion that the document was obtained as proof of success in a case, and the belief that his suspension was automatically lifted—constitute valid defenses for his non-compliance with the Court’s order.
Whether financial necessity can be accepted as a valid excuse for a lawyer’s failure to adhere to court orders and for accepting new cases during a period of suspension.