Title
Sevandal vs. Adame
Case
A.C. No. 10571
Decision Date
Nov 11, 2020
Atty. Sevandal encroached on Atty. Adame's NLRC case representation, violating CPR Rule 8.02, leading to a one-year suspension and P300,000 refund to Merlina. Atty. Adame cleared of misconduct.

Case Summary (A.C. No. 10571)

Petitioner and Respondent

Petitioner/Complainant: Atty. Virgilio A. Sevandal
Respondent: Atty. Melita B. Adame
Client: Merlina Borja-Sevandal, surviving spouse of a seafarer

Key Dates and Agreements

• February 2, 2011 – Verbal agreement between Sevandal and Merlina for a 10% contingent fee.
• March 9, 2011 – Written retainer contract covering conjugal partnership and legitime claims before the RTC.
• April 25, 2011 – Alleged addendum expanding Sevandal’s engagement to death and monetary benefits before various agencies, with a 20% fee.
• May 3, 2011 – Adame filed an NLRC complaint on behalf of Merlina for death benefits and related claims.
• May 24, 2011 – Merlina executed a revocation of the retainer contract with Sevandal.

NLRC Proceedings and Dispute over Representation

After Adame lodged the NLRC complaint, Sevandal filed a manifestation withdrawing the complaint and a formal entry of appearance, attaching a photocopy of the addendum. He attended mandatory conferences, objected to Adame’s representation under Rule 8.02, and later filed an Ex Parte Motion for Attorney’s Lien seeking 20% of any award. The NLRC approved a compromise for ₱300,000 attorney’s fees to Sevandal, conditioned on his signing a general release.

IBP-CBD Investigation and Recommendation

On September 6, 2011, Sevandal lodged a disbarment complaint with the IBP Commission on Bar Discipline (IBP-CBD), invoking Rules 8.02 (encroachment) and 10.01 (falsehood) of the Code of Professional Responsibility. The Investigating Commissioner found no violation by Adame, dismissed the complaint, and recommended that Sevandal be held administratively liable for encroachment and improperly receiving ₱300,000 without authority.

IBP Board of Governors’ Resolutions

• March 21, 2013 – IBP Board adopted the IBP-CBD report dismissing the complaint against Adame.
• March 22, 2014 – Motion for reconsideration by Sevandal denied; he was ordered to show cause for encroachment and unauthorized acceptance of fees.
• November 28, 2017 – IBP-CBD recommended suspension of Sevandal for two years and restitution of ₱300,000. The IBP Board adopted this recommendation and transmitted the case to the Supreme Court under Rule 139-B, Rules of Court.

Issue Presented

Whether Sevandal violated Rule 8.02, Canon 8 (encroachment) and Rule 10.01, Canon 10 (falsehood) of the Code of Professional Responsibility, warranting suspension and restitution.

Supreme Court’s Analysis and Ruling

Under the 1987 Constitution, the Court found that Sevandal had no authority to appear in the NLRC proceedings, which were filed and prosecuted exclusively by Adame. His retainer covered only RTC civil matters; the April addendum was dubious in scope and

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