G.R. No. L-36662-63 - People vs. Camano

Accused Filomeno Camano, who had been sentenced to death, submitted a letter on July 6, 1973, requesting that his former counsel in the lower court, Atty. Alfredo R. Tria, be appointed as his attorney de oficio for his appeal before the Supreme Court.
The letter constituted a formal request for legal representation in a matter of high stakes, given the gravity of the sentence imposed on Camano.

On August 2, 1973, the Court issued a resolution requiring Atty. Alfredo R. Tria to comment on Camano’s July 6 letter within ten days.
On October 1, 1973, noting that respondent Tria had not filed the required comment, the Court appointed Attorney Deogracias Eufemio as counsel de oficio for Camano.
Concurrently, the Court required Atty. Tria to explain and show cause for his failure to comply with its earlier resolution.

Atty. Tria submitted his explanation on October 24, 1973, wherein he detailed the following:

Upon receiving the letter dated July 6, 1973, he dictated to his clerk, Miss Salvacion Lopez, his letter of acceptance to serve as counsel de oficio and directed her to mail it.
He subsequently left for Cebu City on August 16, 1973, returning to Naga City on August 24, 1973.
He discovered only on October 3, 1973, that the letter of acceptance had not been mailed by his clerk.
He asserted that there was no intention to ignore or disobey the Court’s order; the failure was due to an unintentional oversight.

The Court noted that similar instances of neglect regarding the duties owed to judicial tribunals by members of the bar had recently been encountered.
It emphasized the importance of being vigilant in complying with court orders to maintain the integrity and efficiency of judicial proceedings.
The explanation provided by Atty. Tria was carefully scrutinized in the context of these broader concerns regarding carelessness.

Whether Atty. Alfredo R. Tria’s failure to ensure the mailing of his letter of acceptance constituted a neglect of his professional duties toward the Court.

The issue centered on whether his explanation of an unintentional oversight sufficed as a valid excuse.
The matter also involved whether his negligence warranted a corresponding penalty or merely an admonition.

The propriety of the Court’s action in substituting counsel de oficio and admonishing Atty. Tria.

Determining if the appointment of Attorney Deogracias Eufemio, despite Atty. Tria’s explanation, was justified.
Evaluating the extent to which the Court should tolerate oversight or minor lapses, even in the absence of the intent to disobey the Court’s order.