A.C. No. 13995 - Palma vs. Maduramente

Complainant Jhycke G. Palma, president of a homeowner's association named The Great Warrior, engaged the services of respondent lawyer Ladimir Ian G. Maduramente.
Maduramente represented The Great Warrior in several legal cases, including two central disputes: Civil Case No. 6502-3 before the Municipal Trial Court in Cities of General Santos (MTCC) and Civil Case No. 8506 before the Regional Trial Court (RTC) of General Santos City.

The case involved an injunction against Palma and persons under her claiming rights over certain lands.
Plaintiffs moved to declare Palma's group in default due to Maduramente's failure to file an Answer on time.
Though the MTCC allowed a belated Answer, Maduramente failed to appear at pre-trial conference and did not file a pre-trial brief.
Consequently, the MTCC declared Palma’s group in default, allowing only plaintiffs to present evidence, resulting in a judgment in plaintiffs’ favor.
Maduramente filed a motion for reconsideration, which was denied, and a late notice of appeal that was not given due course.
Palma repeatedly requested Maduramente to withdraw; he eventually did so after delay, surrendering case records.

This case was an action for the Declaration of Nullity of Sale, Cancellation of Certificate of Title, and Damages.
Palma’s group intervened claiming superior rights over the disputed property.
Maduramente also represented plaintiffs in this case, creating an alleged conflict of interest.

Maduramente claimed he missed the MTCC pre-trial conference because he was in Manila and provided his ticket as proof.
He argued that Palma, not him, failed to appear at the pre-trial conference.
The late filing of the notice of appeal was attributed to staff inadvertence.
Regarding Case No. 8506, he denied conflict of interest, stating he represented Palma's group solely to assist with harassment issues, and filed intervention to save on expenses.

Integrated Bar of the Philippines-Commission on Bar Discipline (IBP-CBD) found Maduramente administratively liable for negligence and conflict of interest.
Failure to attend pre-trial conference, failure to file pre-trial brief, disregard of court orders, and late filing of appeal demonstrated gross negligence violating Canons 17 and 18 of the CPR.
Representation of both plaintiffs and complainant’s group in the same RTC case was a clear conflict of interest violating Canon 15, Rule 15.03 of the CPR.
IBP Board of Governors (BOG) affirmed liability, but modified penalty due to respondent’s prior disbarment to a fine of PHP 100,000.

Whether Maduramente is administratively liable for gross negligence in handling Civil Case No. 6502-3.
Whether Maduramente violated the rule against conflict of interest by representing opposing interests in Civil Case No. 8506.
What penalty should be imposed considering his previous disbarment.