G.R. No. 194328 - Stronghold Insurance Co., Inc. vs. Interpacific Container Services

In October 2001, complainant Dolores D. PariAas engaged respondent Atty. Oscar P. Paguinto to annul her marriage to Danilo Soriano.
The parties agreed on an acceptance fee of ₱25,000, in addition to a filing fee of ₱2,500 and other incidental expenses.
On December 2, 2001, PariAas paid Paguinto ₱10,000 in cash as a partial payment for the acceptance fee, evidenced by an acknowledgment receipt.
PariAas provided a diskette narrating the events involving her and her estranged husband, as well as a copy of her marriage contract with Soriano, to assist Paguinto in handling the annulment case.
Before the end of December 2001, PariAas also paid ₱2,500 for the filing fee.

Between January and April 2002, PariAas inquired about the progress of her annulment case. Paguinto informed her that the case had been filed at the Regional Trial Court of Manila, Branch 64, before Judge Ricaforte, with a hearing scheduled on April 25, 2002.
Prior to the scheduled hearing, PariAas requested a meeting with Paguinto; however, she was told by his secretary that the hearing had been canceled and that subsequent hearings (originally set for May 29 and June 26, 2002) were postponed due to the judge's illness or absence.
In the first week of July 2002, when PariAas personally visited RTC-Manila, Branch 64, she was informed there was no record of her case filed in that court.
Upon asking, Paguinto stated that the relevant records were in his office because he was attending another case in Malolos, Bulacan, thereby misleading PariAas about the status of her annulment case.

After discovering that the annulment case was never filed, Paguinto promised to refund the money advanced by PariAas.
The ₱10,000 paid as partial acceptance fee was only returned after PariAas filed a complaint with the Commission on Bar Discipline (CBD) under the Integrated Bar of the Philippines (IBP).
On February 14, 2003, the CBD ordered Paguinto to answer the complaint, and on March 19, 2003, an extension for filing his answer was granted.
Paguinto failed to file his answer within the extended period, leading the CBD to declare him in default on July 15, 2003.

On September 10, 2003, PariAas filed an Affidavit of Withdrawal, stating that her complaint had arisen from a misapprehension of facts, misunderstanding, and miscommunication.
On the same date, Paguinto submitted a Manifestation and Motion, offering an explanation for his absence at a hearing on July 30, 2003—attributing it to his attendance at a criminal case in Tabuk, Kalinga—and apologized for his shortcomings, admitting sole responsibility for his errors.

The IBP designated Atty. Rebecca Villanueva-Maala as Commissioner to investigate the case.
The Commissioner found that Paguinto was negligent in performing his duties as a lawyer and officer of the court, specifically for failing to file the annulment case and for mishandling the client’s funds.
Based on the investigation, the Commissioner recommended the suspension of Paguinto from the practice of law for six months.

The Court agreed with the findings of the Commissioner, noting that Paguinto had led PariAas to believe that her case was filed and had failed to properly account for the funds given.
The Court emphasized that accepting money from a client creates a fiduciary duty and that money collected for a specific purpose must be immediately returned if not used accordingly.
Paguinto’s delay in returning the money until after administrative proceedings had commenced was highlighted as a breach of duty.
Ultimately, the Court penalized Paguinto with a six-month suspension from practicing law, with the suspension effective upon receipt of the Decision.
Copies of the Decision were ordered to be furnished to the Office of the Bar Confidant, the IBP, and all courts for guidance.

Whether Atty. Paguinto breached his duty of diligence, care, and skill by misrepresenting the status of the annulment case and failing to file it with the appropriate court.
Whether his actions in mishandling the client’s funds—specifically, accepting payment for services not rendered and delaying the refund—constitute a violation of the Code of Professional Responsibility.
Whether the withdrawal of the administrative complaint by the complainant exonerates Paguinto from disciplinary action.
Whether the failure to appear at hearings and adequately prepare the case demonstrates negligence that merits suspension from practice.