G.R. No. 213816 - Luces vs. Coca-Cola Bottlers Philippines, Inc.

The case involves disbarment proceedings against two attorneys: Atty. Henry B. So for alleged neglect in handling a case and Atty. Ferdinand L. Ancheta for allegedly extorting ₱200,000 from his client.
Complainants: Gabino V. Tolentino and his wife, Flordeliza C. Tolentino.
The underlying legal matter stemmed from Civil Case No. SC-2267, “Benjamin Caballes v. Flordeliza Caballes,” involving the recovery of possession of a parcel of land.

June 24, 1991 – The Regional Trial Court of Sta. Cruz, Laguna, rendered a decision ordering complainant Flordeliza to vacate the land.
The decision was appealed to the Court of Appeals through counsel Atty. Edilberto U. Coronado.
Atty. Coronado was subsequently replaced by Atty. Henry B. So, a lawyer of the Bureau of Agrarian Legal Assistance (BALA) of the Department of Agrarian Reform, while the appeal was pending.
Complainants later discovered the Court of Appeals had affirmed the decision against Flordeliza, which led them to allege that Atty. So failed to inform them or take necessary steps to elevate the case to the Supreme Court.

Due to the perceived inaction by Atty. So, the complainants engaged Atty. Ferdinand L. Ancheta, paying him an acceptance fee of ₱30,000.
Atty. Ancheta promised that a “motion to reopen” the appeal could be filed despite the Court of Appeals’ decision having attained finality.
He further proposed a scheme that involved depositing ₱200,000 purported for arranging meetings with the justices of the Court of Appeals through bribery.
Initially, the complainants were reluctant, but eventually, in January 2003, they deposited ₱200,000 into Atty. Ancheta’s bank account.

Complainants later learned that no motion to reopen the case was filed and that the appellate decision was final and executory.
In response, via their new counsel, they demanded the return of the ₱200,000 on September 10, 2003, which Atty. Ancheta ignored.
On May 17, 2004, the complainants filed their Sinumpaang Sakdal, seeking the disbarment of both respondents for their respective alleged misconduct.
Atty. So submitted a comment, contending that he had resigned from the Bureau as early as 1997—well before the final decision of the Court of Appeals on July 16, 2001.
Atty. Ancheta failed to file any comment despite due notice and was eventually deemed to have waived his right to respond in writing.

The case was referred to the Integrated Bar of the Philippines (IBP) for investigation and recommendation.
A mandatory conference was set on July 6, 2011, with only Atty. So appearing; hence, the meeting was rescheduled to August 10, 2011.
During the August 10 conference, complainant Flordeliza was represented by her daughter and counsel, while Atty. So did submit his position paper on September 15, 2011; Atty. Ancheta did not file a position paper.
The IBP Commission on Bar Discipline later recommended absolving Atty. So for lack of evidence of negligence, but found Atty. Ancheta guilty of serious misconduct and deceit, recommending his disbarment.

On December 14, 2014, the IBP Board of Governors adopted the recommendations, and these findings were transmitted to the Supreme Court on January 11, 2016.
The Supreme Court, acting in an en banc resolution dated July 19, 2016, accepted the findings: Atty. So was absolved due to the procedural context and his clear lack of connection at the time of the decision, whereas Atty. Ancheta’s misconduct, including deceit, extortion, and failure to perform his duties, warranted his disbarment.
Further, Atty. Ancheta was ordered to return the funds (₱230,000.00, combining the acceptance fee and the bribery funds) along with accrued legal interest, and to comply with additional orders regarding proof of payment.

Whether Atty. So’s failure to inform the complainants and to take steps to elevate the case to the Supreme Court constituted grounds for disbarment or other disciplinary sanctions.
Whether his status as a former government-employed lawyer at the Bureau of Agrarian Legal Assistance affected his responsibilities over the case.

Whether Atty. Ancheta’s actions in extorting ₱200,000 from his clients, by proposing bribery to influence the justices of the Court of Appeals, constituted gross professional misconduct.
Whether his failure to file the promised “motion to reopen” and subsequent non-compliance with multiple court resolutions aggravated his misconduct.
Whether the evidence available supported a charge of deceit, abuse of trust, and dereliction of his duties as a lawyer.

Whether the complainants’ own actions or inaction in following up on the appeal status contributed to the adverse outcome.
Whether a lawyer can be held accountable for failing to secure a favorable judgment if the client also neglected to follow up on the progress of the case.