Facts:

• The case involves Adelita S. Villamor (complainant) and Atty. Ely Galland A. Jumao-as (respondent).
• Villamor was persuaded by Felipe Retubado and Atty. Jumao-as to establish a lending company.
• Retubado was to manage daily operations, while Atty. Jumao-as would handle legal matters.
• Villamor agreed, and Atty. Jumao-as registered AEV Villamor Credit, Inc. with the SEC and drafted necessary legal documents, including the Articles of Incorporation (AOI).
• In March 2007, Atty. Jumao-as requested Villamor to sign blank SEC pre-printed AOI forms.
• He later informed her about a loan from Debbie Yu, delivering P500,000.00 as additional capital for the business.
• A promissory note was prepared, but Villamor did not receive a copy nor met Yu.
• In April 2008, Atty. Jumao-as instructed Villamor to issue a postdated check for P650,000.00 to Yu as loan security, assuring her it would not be negotiated.
• In May 2008, Atty. Jumao-as and Retubado left Villamor's company to join Yu's new lending company, attempting to persuade her collectors to abandon her.
• On October 8, 2008, Atty. Jumao-as sent a demand letter to Villamor on behalf of Yu, prompting Villamor to file a complaint against him for violating the Code of Professional Responsibility (CPR).
• Atty. Jumao-as denied any lawyer-client relationship with Villamor, claiming he was only engaged by Retubado for incorporation.
• The Investigating Commissioner found Atty. Jumao-as guilty of representing conflicting interests and recommended a one-year suspension, which was later modified to two years by the Board of Governors.
• Atty. Jumao-as sought reconsideration, claiming Villamor had filed an Affidavit of Desistance, but the IBP denied his motion.

Issue:

• (Unlock)

Ruling:

• Yes, Atty. Jumao-as violated the Code of Professional Responsibility by representing conflicting interests.
• Yes, a lawyer-client relationship existed between Atty. Jumao-as and Adelita S. Villam...(Unlock)

Ratio:

• The Supreme Court upheld the IBP's findings that Atty. Jumao-as represented conflicting interests, prohibited under Canon 15, Rule 15.03 of the CPR.
• The Court emphasized the necessity for a lawyer to maintain loyalty and fairness in client dealings.
• A conflict of interest arises when a lawyer represents clients with opposing interests, evident when Atty. Jumao-as sent a demand letter to Villamor on behalf of Yu.
• The Court clarified that a lawyer-c...continue reading