Title
Supreme Court
Martin vs. Dela Cruz
Case
A.C. No. 9832
Decision Date
Sep 4, 2017
A lawyer was suspended for six months for neglecting a client’s cases, failing to attend hearings, and refusing to return a P60,000 acceptance fee despite rendering no legal services.

Case Summary (A.C. No. 9832)

Allegations Against the Respondent

The complainant alleged a lack of action from the respondent relating to her cases, which culminated in her repeated inquiries and demands for the return of the acceptance fee. Respondent's non-compliance included failing to appear in hearings, not responding to the complainant’s communications, and ultimately denying her requests for a refund of the fee. Several attempts by the complainant to address these issues through various complaints to higher authorities, including the Office of the Ombudsman and the Office of the President, were made without any resolution.

The IBP Proceedings

Upon referral from the Court, the Integrated Bar of the Philippines (IBP) investigated the matter. A mandatory conference was convened on June 2, 2014, attended only by the complainant. Follow-up compliance was demanded, yet respondent's absence persisted, further establishing a pattern of neglect.

Findings of the Investigating Commissioner

The Investigating Commissioner (IC) concluded that respondent had indeed violated several provisions of the Code of Professional Responsibility (CPR), specifically noting failures in rendering legal services, attending hearings, and refusing to return the fee. As a result, the IC recommended a one-year suspension from practice and an order for reimbursement of the acceptance fee plus interest.

IBP Board of Governors Resolution

In a resolution dated February 20, 2015, the IBP Board of Governors adopted the recommendations of the IC. The respondent's appeal, citing ignorance of the case and procedural discrepancies regarding notice, was subsequently denied by the IBP in September 2016.

Court's Ruling on Admin Liability

The Court affirmed the IBP's findings, concluding that respondent was guilty of neglect and failure to uphold his duties as a lawyer. The provisions of Rules 18.03 and 18.04 of the CPR were unequivocally breached, highlighting that a lawyer must diligently serve and keep the client informed about their case. The Court emphasized that his negligence amounted to inexcusable conduct warranting administrative liability.

Respondent's Penalty and Restitution

The Court decided on a six-month suspension, align

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