Title
Supreme Court
Saura, Jr. vs. Agdeppa
Case
A.C. No. 4426, 4429
Decision Date
Feb 17, 2000
Atty. Agdeppa fined P2,000 for failing to disclose property sale details to co-heirs, violating professional ethics; due process upheld, attorney-client privilege inapplicable.

Case Digest (A.C. No. 4426, 4429)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Two petitions were filed:
      • One by Ramon Saura, Jr.
      • Another by Helen S. Baldoria and Raymundo Y. Saura.
    • Both petitions charged Atty. Lalaine Lilibeth Agdeppa with violating her lawyer’s oath and disregarding specific provisions (Canons 15, 22, 25, 29, 31, and 32) of the Canons of Professional Ethics.
  • Dispute Over the Intestate Estate
    • The controversy arose from the settlement of a property owned in common by the petitioners and their siblings (Macrina, Romeo, and Amelita Saura).
    • The property was part of the intestate estate of the late Ramon E. Saura, who died intestate on May 15, 1992.
  • Alleged Misconduct and Transaction Details
    • Negotiations for the settlement of the property dragged on for three years.
    • On April 27, 1995, the petitioners discovered that:
      • The administrators (the petitioners’ siblings) had sold the property to Sandalwood Real Estate and Development Corporation.
      • Atty. Agdeppa had assisted in the transaction by notarizing the Deed of Sale.
    • Petitioners alleged that:
      • They were not informed or involved in the sale.
      • Despite repeated demands, the respondent refused to disclose the sale amount or account for the proceeds, thus compelling them to institute criminal and civil actions to protect their rights.
  • Procedural and Administrative Developments
    • The case was referred by the Supreme Court to the Integrated Bar of the Philippines (IBP) in 1995 after an earlier resolution was returned as “unclaimed.”
    • On February 5, 1998, at a scheduled hearing:
      • Petitioners’ counsel, Atty. Carolina Esguerra-Ochoa, appeared, filing a written entry of appearance.
      • No appearance was logged for Atty. Agdeppa.
    • Efforts to serve the respondent:
      • The IBP noted a new address provided by Atty. Ochoa and suggested furnishing the respondent with copies of the complaint and accompanying documents.
      • A compliance dated February 10, 1998, confirmed that the respondent had been served with a copy of the petition, Supreme Court resolutions, and court orders.
      • A return card dated March 2, 1998, evidenced the receipt of documents by the respondent.
    • To date, Atty. Agdeppa failed to file any response.
  • Disciplinary Findings and Sanctions Imposed
    • Due to her repeated disregard for the court orders and failure to answer the charges, the IBP recommended penalizing her with:
      • A fine of P10,000.00.
      • Suspension from practice for one year in each of the two pending cases.
    • The Court, emphasizing her defiance and non-cooperation, resolved:
      • To impose a fine of P2,000.00, payable within ten days.
      • To impose a penalty of imprisonment for five days if the fine was not paid.
      • That the resolution would be immediately executory.

Issues:

  • Due Process and Right to be Heard
    • Whether Atty. Agdeppa was denied her due process right by not being provided an effective opportunity to answer the administrative charges.
    • Whether her alleged change of address and subsequent non-receipt of earlier notices can justify her failure to respond.
  • Applicability of Attorney-Client Privilege
    • Whether the requirement to disclose the sale amount and account for the proceeds from the property sale infringes on the attorney-client privilege.
    • Whether such confidential communications in the context of a settlement dispute are protected from disclosure.
  • Compliance with the Court’s Orders and Ethical Obligations
    • Whether Atty. Agdeppa’s disregard of the court’s orders and subsequent silence violates the ethical standards enshrined in the Canons of Professional Ethics.
    • Whether her non-compliance amounts to an evasion of accountability and a breach of her duty to uphold the integrity of the legal profession.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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