Case Digest (A.C. No. 13982)
Facts:
Myrna Gomez Stewart v. Atty. Crisaldo R. Rioflorido, A.C. No. 13982 (Formerly CBD Case No. 19-5970), July 17, 2024, the Supreme Court Third Division, Gaerlan, J., writing for the Court. Complainant Myrna Gomez Stewart engaged Atty. Crisaldo R. Rioflorido to handle criminal cases she filed against her husband (VAWC under RA 9262 and concubinage). They executed an Engagement Agreement dated April 12, 2018, under which Stewart initially paid Php 100,000 (Php 60,000 acceptance fee; Php 40,000 for legal expenses) and later paid an additional Php 30,000, bringing the total to Php 130,000. Stewart turned over pertinent documents and repeatedly sought updates from Atty. Rioflorido by text and email between May and October 2018; she alleged that he gave assurances he could influence the prosecutor and promised to follow up but thereafter became unresponsive and refused to return her documents and funds despite demands.Stewart filed a Complaint-Affidavit with the Integrated Bar of the Philippines (IBP) Commission on Bar Discipline (CBD), alleging violations of the Code of Professional Responsibility (CPR). In his Verified Answer, Atty. Rioflorido denied promising to influence the prosecutor and asserted he communicated with Stewart. The CBD (Investigating Commissioner Maria Raquel S. Chavez) found him administratively liable for violation of Canons 17 and 18 and the Lawyer’s Oath, recommending one year’s suspension and return of the money and documents.
The IBP Board of Governors, by Resolution No. CBD-XXV-2023-06-53 dated June 9, 2023, approved and adopted the CBD recommendation but directed respondent to return Php 100,000 with leg...(Pro-only)
Issues:
- Did Atty. Crisaldo R. Rioflorido violate the Code of Professional Responsibility and Accountability (CPRA) by failing to keep his client informed and by failing to render legal services diligently?
- Did Atty. Rioflorido unjustifiably fail or refuse to render an accounting and to turn over client documents upon termination of engagement?
- Does his failure to return the client’s funds give rise to the presumption of misappropriation and warrant more severe disciplinary san...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)