G.R. No. 11597 - People vs Padilla

The administrative case arose from a sworn Complaint-Letter dated November 20, 2013, filed by Adela Hernandez Violago (complainant) against Atty. Bonifacio F. Aranjuez, Jr. (respondent).
Complainant, a member of the E. Quiogue Extension Neighborhood Association, was also one of the defendants in an ejectment suit involving the Estate of Francisco De Borja.
Respondent represented the Neighborhood Association in the ejectment case that was docketed as Civil Case No. 1352-10, handling proceedings from the trial court up to the Supreme Court level.
The administrative case was subsequently referred to the Integrated Bar of the Philippines (IBP) and docketed as CBD Case No. 15-4627 for investigation, report, and recommendation.

Complainant claimed she was not properly informed regarding the status of the petition for review filed by respondent on behalf of the Neighborhood Association.
It was only after an inquiry made on October 16, 2013, that complainant discovered the petition had been dismissed by the Court of Appeals on July 25, 2013, due to several material defects.

The Court of Appeals explained that the petition had five material defects including the failure to attach necessary pleadings, errors in the Verification and Certification on Non-Forum Shopping, inconsistencies in names, omission of required MCLE compliance details, and discrepancies in the method of service of the petition.
Complainant consulted with various lawyers who opined that these mistakes were “basic” and should have been avoidable.

On November 06, 2013, complainant, along with another Neighborhood Association member, submitted a Resignation Letter informing the association’s officers of their decision to resign and expressing their intent to engage a different counsel.
In the same letter, they requested that respondent file a formal Motion to Withdraw as their counsel in the ejectment case.
Complainant alleged that respondent failed to act on the request or provide any reply, which led her to file the administrative case on November 20, 2013.

Respondent maintained that he represented the Neighborhood Association pro bono at the request of then-Mayor of Pateros, Joey Medina, to assist indigent litigants.
He asserted that he maintained coordination and regular communication with the association’s officers, although he rarely had direct personal contact with complainant.

Respondent stated that he did, in fact, file a formal motion for his withdrawal which was noted by the Supreme Court when requested by complainant during a chance meeting at the Municipal Hall.
He denied any negligence, contending that he exerted earnest efforts by filing several pleadings and taking the case through various court levels despite the technical deficiencies identified.

Through his Omnibus Motion dated August 27, 2013, respondent attempted to remedy the defects by submitting additional documentary evidence and clarifications, arguing that some deficiencies were merely typographical or clerical errors.
Despite these efforts, the Court of Appeals denied the motion on substantive grounds, prompting respondent to file a Petition for Review on Certiorari before the Supreme Court.

Commissioner Erwin L. Aguilera, in his Report and Recommendation dated May 03, 2017, recommended a three (3) year suspension for respondent, stating that the failure to comply with basic rules in filing pleadings was a manifestation of negligence.
The IBP Board of Governors, in its Resolution dated February 22, 2018, adopted the findings with modifications, reducing the penalty from a three-year suspension to a six (6) month suspension.

Whether respondent should be administratively disciplined for negligence in handling the ejectment case on behalf of complainant.

Specifically, whether the material defects in the Petition for Review constitute gross and inexcusable negligence.

Whether the imposition of an administrative penalty (suspension versus a lesser sanction) is warranted under the circumstances.
The extent to which respondent’s efforts to remedy the defects, including the filing of an Omnibus Motion, mitigate or exempt him from gross negligence.