A.C. No. 11959 - Sison vs. Dumlao

In July 2013, Dr. Eusebio D. Sison consulted Atty. Lourdes Philina B. Dumlao, his friend, to file an annulment case against his wife and deposited ₱35,000.00 for a psychiatric evaluation.
Atty. Dumlao referred him to psychologist Mr. Nhorly Domenden, who conducted the evaluation and emailed the Psychological Evaluation Report in November 2013.

A series of text messages (August 29, September 24–26, October 5–8, February 26 2014) show respondent requesting and receiving case documents, promising to file the complaint, and arranging meetings.
Before November 2013, Dr. Cynthia Sison’s mother (a fifth-degree relative by consanguinity) requested respondent to decline representation due to family concerns; respondent failed to inform Dr. Sison of her withdrawal.

In February 2015, the Investigating Commissioner found no written contract but acknowledged that the fee was applied to the psychological evaluation; he recommended dismissal based on valid conflict of interest. The IBP Board of Governors adopted this recommendation on June 5 2015 and denied reconsideration on April 19 2017.
Dr. Sison filed a Petition for Review on Certiorari before the Supreme Court, alleging that a lawyer-client relationship existed and that respondent violated Canons 7, 17, 18 of the Code of Professional Responsibility and the Lawyer’s Oath by not informing him of the case status and her withdrawal.

Whether a lawyer-client relationship was established between Dr. Sison and Atty. Dumlao despite the absence of a written contract or payment of legal fees beyond the psychiatric evaluation.
Whether Atty. Dumlao violated the Code of Professional Responsibility—specifically Canon 18, Rules 18.03 and 18.04—by failing to serve with due diligence and by not informing Dr. Sison when she declined further representation due to conflict of interest.