G.R. No. 166730 - Spouses Torres vs. Medina

This is a disbarment complaint filed by Simon D. Paz (complainant) against Atty. Pepito A. Sanchez (respondent) for allegedly representing conflicting interests and violating the lawyer’s oath.
The controversy arose from respondent’s handling of property transactions involving several parcels of land in Pampanga that were purchased by complainant and his partners, Alfredo Uyecio and Petronila Catap.

In 1995, complainant and his partners engaged respondent’s services to assist in both the purchase and proper documentation of several parcels of land, in addition to defending their title against claims by George Lizares in cases where respondent served as counsel.
As part of his engagement, respondent represented complainant in litigation against Lizares while also becoming involved in matters affecting a property owned by Isidro Dizon, a tenant-farmer whose property (covered by Emancipation Patent No. 00708554/Transfer Certificate Title No. 25214) was among those transacted.

Complainant alleged that after respondent’s supposed termination of services in May 2000, respondent filed a complaint before the Department of Agrarian Reform Board (DARAB) on behalf of Isidro Dizon for the annulment of TCT No. 420127-R in complainant’s name.
Further allegations involved using complainant’s outdated address to serve the complaint, thereby enabling a default judgment in favor of Dizon, which the complainant contended was the result of “malicious machination.”

On 23 June 2003, respondent filed a civil case before the Regional Trial Court (RTC) challenging TCT No. 483629-R, which had been transferred to Sycamore Venture Corporation (with which complainant was associated) by allegedly relying on the irregularities of the earlier DARAB case.
Complainant maintained that respondent’s failure to disclose the pending petition before the DARAB case and his subsequent filing of the RTC case amounted to forum shopping and submission of a false certification regarding non-forum shopping.

In his comment, respondent clarified that he had represented the tenant-farmers, including Dizon, since 1978 and that his involvement with complainant began when complainant and his partners, lacking legal counsel of their own, allowed him to represent them.
He contended that the DARAB complaint had been filed on 15 May 1997 (not after his termination in May 2000) out of a sense of responsibility for the cancellation of TCT No. 25214, and that the complainant and his partners had been duly notified as evidenced in the 20 August 2002 DARAB decision.
On the RTC case, he explained that the suit arose upon discovering the transfer of the title in question, and maintained that his cases were justifiable, tenable, and meritorious, denying any act of forum shopping.

The Integrated Bar of the Philippines (IBP) became involved after a Resolution dated 12 November 2003 referred the case for investigation, report, and recommendation.
Commissioner Milagros V. San Juan convened a mandatory conference on 4 March 2004, with both parties submitting position papers.
The IBP Board of Governors, in Resolution No. XVI-2005-78 dated 12 March 2005, modified Commissioner San Juan’s recommendation and found respondent guilty of violating the prohibition against representing conflicting interests, recommending a one-year suspension with a warning of harsher penalties for any future offense.

Whether Atty. Pepito A. Sanchez committed forum shopping or filed groundless suits by pursuing parallel litigation in the DARAB and RTC cases.

Determining if representing conflicting interests automatically leads to forum shopping when litigation involves related properties and transactions.
Evaluation of whether the distinct reliefs sought in the two cases could differentiate them, thus negating a claim of forum shopping.

Whether respondent violated the lawyer’s oath by filing suits that were alleged to be groundless or false.

Assessment of the factual basis for the claims made in both the DARAB and RTC cases and the potential for dishonest practices.

Whether respondent’s simultaneous representation of conflicting parties—namely, complainant in the Lizares cases and Dizon in the DARAB case—constitutes a breach of the Code of Professional Responsibility.

Analysis of the applicability of Rule 15.03 on representation of conflicting interests without written consent after full disclosure.