Title
Spouses Saunders vs. Pagano-Calde
Case
A.C. No. 8708
Decision Date
Aug 12, 2015
Lawyer reprimanded for mishandling P500,000 client funds, violating fiduciary duty, and presenting dubious evidence, despite pending estafa case.

Case Summary (G.R. No. L-5691)

Background of the Complaint

The case arose from a complaint filed by Byron and Maria Luisa Saunders against Atty. Lyssa Grace S. Pagano-Calde for misappropriating P530,000. The Saunders sought legal services from Pagano-Calde regarding a property transaction involving their brother, Virgilio J. Gaerlan, for which a Deed of Conditional Sale was allegedly executed. The complainants provided Pagano-Calde with funds to be held in trust for their mother, Adelia J. Gaerlan, as part of this transaction and incurred additional expenses related to it.

Allegations and Claims

Following the unsuccessful transaction, the complainants attempted to retrieve their funds. Pagano-Calde responded by asserting the money was secured in a term deposit. However, she could not provide any documentation to substantiate her claim. Complainants accused her of refusal to meet and discuss the status of the ongoing civil case and the funds. Contrarily, Pagano-Calde claimed the sum was delivered to Adelia in November 2005 as per the Conditional Sale agreement, providing an Acknowledgment Receipt allegedly signed by Adelia, which was later disputed by the complainants.

Initiation of Criminal Proceedings

Due to Pagano-Calde’s failure to return the funds, the complainants filed a criminal case for estafa, asserting that the Acknowledgment Receipt was fabricated and introduced only post-filing of the criminal complaint. The investigation revealed multiple testimonies and an NBI report indicating discrepancies in the signature on the receipt. This context led to the filing of an administrative complaint with the Integrated Bar of the Philippines.

Findings of the IBP Commission

The IBP Commission on Bar Discipline concluded it could not resolve the issue of Pagano-Calde’s alleged misappropriation due to the ongoing criminal proceedings, recommending the dismissal of the complaint without prejudice. This recommendation was adopted by the Board of Governors.

Supreme Court Ruling

The Supreme Court rejected the IBP-CBD's recommendation, clarifying that disciplinary actions against lawyers are independent of any criminal proceedings. It emphasized the necessity of maintaining the integrity of the legal profession and highlighted that administrative accountability does not hinge upon the outcomes of criminal cases.

Breach of Professional Conduct

The Court identified clear breaches of the professional conduct expected from lawyers, specifically pointing to the Code of Professional Responsibility, including Canons 16 and 17, which mandate that lawyers maintain trust in h

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