G.R. No. 92163 - Enrile vs. Salazar

Federico C. Suntay, the complainant, alleged misconduct against his nephew, Atty. Rafael G. Suntay, the respondent, who once acted as his legal counsel, adviser, and confidant from 1956 to 1964.
Their professional and personal relationship deteriorated in 1964, primarily due to political differences and respondent’s overweening political ambitions.

Complainant contended that respondent, having benefited from privileged, confidential information during their attorney-client relationship, later used such information to initiate litigation and harass him.
The respondent was accused of filing several cases against the complainant, which included:

Civil Case No. 4306-M, “Carlos Panganiban v. Dr. Federico Suntay” (1975), involving issues on the administration of fishponds.
Civil Case No. 4726-M, “Narciso Lopez v. Federico Suntay” (1970), concerning the determination of the real contract over the fishponds.
Civil Case No. 112764, “Magno Dinglasan v. Federico Suntay,” seeking damages based on similar factual underpinnings involving fishpond administration.
I.S. No. 77-1523, “Magno Dinglasan v. Federico Suntay,” for charges of false testimony and grave oral defamation before the Office of the Provincial Fiscal of Bulacan.

During the period of representation, respondent was privy to all of complainant’s legal, financial, and political affairs.
The close relationship involved the handling of matters like property titling, fishpond administration, and political advisement, thereby establishing deep trust and confidentiality.

It is alleged that respondent gained confidential data, notably from the Transfer Certificate of Title No. T-15674 and the blueprint plan, which showed the existence and later disappearance of two creeks (Sapang Malalim and Sapang Caluang) traversing one of the complainant’s fishponds in Bulacan.
Using this information, respondent pursued a separate case for violation of Presidential Decree No. 296 regarding the alleged illegal destruction of dikes.

Respondent acted as counsel for parties adversarial to the complainant in the aforementioned cases, despite his previous obligations.
In particular, his representation of Magno Dinglasan (for both the defamation and damages cases) was highlighted because it involved issues on which he had previously advised complainant.

The Office of the Solicitor General (OSG) conducted an investigation, culminating in its Report and Recommendation dated 14 October 1982, which found respondent guilty of two counts of malpractice, one count of violating confidentiality, and one count of engaging in unethical conduct.
Subsequent to several procedural delays and motions, the matter was turned over to the Integrated Bar of the Philippines (IBP), which in Resolution No. XIV-2001-169 (dated 29 April 2001) recommended a two-year suspension against respondent.

Respondent filed a motion for the complainant to specify the confidential information supposedly misused; however, this defense was found insufficient given the overall misconduct.
The prolonged proceedings involved motions for remand, disqualification of the appointed Solicitor General’s representative, and suspension of filing periods, eventually leading to the IBP’s adverse finding and its referral for final adjudication by the Court En Banc.

Whether Atty. Rafael G. Suntay used confidential information obtained during his role as legal counsel for Federico C. Suntay to engage in litigation that adversely affected the complainant’s interests.
Whether respondent’s engagement in representing parties adverse to his former client constitutes malpractice and unethical conduct under the Code of Professional Responsibility.
Whether the filing of cases involving matters on which respondent had prior involvement, including property and fishpond administration disputes, effectively demonstrates a conflict of interest and violation of professional confidentiality.
Whether the defense citing the lack of a specific accusation of “confidential information or intelligence” is sufficient to exculpate respondent from the charges of unethical conduct and malpractice.