Title
Santos-Tan vs. Robiso
Case
A.C. No. 6383
Decision Date
Mar 31, 2009
A lawyer issued a bouncing check to refund fees after minimal progress in a case, leading to a one-month suspension for violating B.P. 22 and professional ethics.
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Case Summary (A.C. No. 6383)

Administrative Complaint Overview

  • Complainant Irene Santos-Tan filed an administrative complaint against Atty. Romeo Robiso for malpractice and issuing a bouncing check.
  • The complaint seeks disbarment and the return of P85,000.00, plus interest.
  • Complainant engaged respondent's services in December 2000, paying an acceptance fee of P100,000.00 for representation in a probate case.

Allegations of Negligence

  • Complainant discovered that only a notice of appearance had been filed by respondent after several months of inactivity.
  • On November 3, 2003, complainant demanded the return of her professional fees due to lack of service.
  • Respondent issued a check for P85,000.00, which was later dishonored for insufficient funds.

Respondent's Defense

  • Respondent claimed that delays were due to the suspension of the regular presiding judge and that he made efforts to follow up on the case.
  • He alleged that the check was issued to stop complainant's verbal abuse and that it was without consideration.
  • Respondent maintained that he was not negligent and had been diligent in his duties.

Complainant's Counterarguments

  • Complainant refuted respondent's claims, asserting that he should have known about the judge's suspension.
  • She argued that it was implausible for her to bully a lawyer and that the check was issued under duress.
  • Complainant provided an affidavit from her sister, Miriam, who corroborated her account of the events.

IBP Proceedings and Findings

  • The Integrated Bar of the Philippines (IBP) conducted hearings and required position papers from both parties.
  • The hearing officer found that while respondent was not grossly negligent, he was liable for issuing a bouncing check.
  • The IBP recommended a one-month suspension and reimbursement of P70,000.00 to complainant.

Court's Resolution on Negligence

  • The Court affirmed the IBP's findings, agreeing that respondent could not expedite the resolution of the pending motions.
  • It noted that the acting presiding judge's reluctance to act on the motions was beyond respondent's control.

Legal Implications of Issuing a Bouncing Check

  • The Court emphasized that issuing a bouncing check constitutes serious miscon...continue reading

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