Case Summary (A.C. No. 1890)
Allegations Against Respondent
Complainant claimed that Respondent filed several complaints and cases purportedly to harass him. These included:
- Civil Case No. 4306-M (1975): Carlos Panganiban v. Federico Suntay, concerning fishponds.
- Civil Case No. 4726-M (1970): Narciso Lopez v. Federico Suntay, regarding contract disputes related to the same fishponds.
- Civil Case No. 112764: Magno Dinglasan v. Federico Suntay, filed for damages.
- I.S. No. 77-1523: Magno Dinglasan v. Federico Suntay, regarding false testimony and grave oral defamation.
Moreover, Respondent pursued a case against Complainant for the alleged illegal disappearance of two creeks traversing Complainant’s fishpond under Presidential Decree No. 296.
Respondent's Motion and Investigation
In response to the allegations, Respondent filed a motion requesting Complainant to specify the confidential information he allegedly misused. The case was then referred to the Office of the Solicitor General (OSG) for investigation, which ultimately took four years. The OSG's report identified two counts of malpractice for Respondent, including violations of confidentiality and unethical conduct.
Findings of Malpractice
The OSG determined that Respondent committed malpractice by representing adversaries against Complainant in cases directly related to matters upon which he had previously advised Complainant. Specifically, he represented:
- Magno Dinglasan in a case involving defamation related to testimony that Complainant provided to Respondent years before.
- Panganiban and Lopez in cases concerning properties managed by Respondent while serving as Complainant's legal adviser.
Unethical Conduct and Use of Confidential Information
Evidence suggested Respondent derived professional advantage from information he learned during his time as Complainant’s lawyer. Despite Respondent's defense that Complainant failed to specify what confidential information was used against him, the legal principles emphasized that lawyers have an obligation to protect client privacy and confidentiality even after the termination of the attorney-client relationship.
Delay in Proceedings and Final Recommendations
Complications included various motions filed by Respondent, leading to delays in the proceedings. A resolution from the Integrated Bar of the Philippines (IBP) recommended a two-year suspension for Respondent due to his unethical conduct. The case eventually advanced to be reviewed by the Supreme Court given t
...continue readingCase Syllabus (A.C. No. 1890)
Case Background
- This case involves a Complaint for disbarment filed by Federico C. Suntay against his nephew, Atty. Rafael G. Suntay.
- The complainant alleges that the respondent was his legal counsel, adviser, and confidant from 1956 to 1964.
- Following a rift due to political ambitions in 1964, the respondent began to file multiple complaints against the complainant, allegedly using confidential information obtained during their attorney-client relationship.
Allegations of Misconduct
- Complainant enumerated several cases filed by the respondent as harassment:
- Civil Case No. 4306-M: "Carlos Panganiban v. Dr. Federico Suntay" for injunction and damages in 1975.
- Civil Case No. 4726-M: "Narciso Lopez v. Federico Suntay" in 1970 involving the same fishponds the respondent helped manage.
- Civil Case No. 112764: "Magno Dinglasan v. Federico Suntay" for damages.
- I.S. No. 77-1523: For false testimony and grave oral defamation, linked to the testimony given by the complainant.
Use of Confidential Information
- The complainant alleged that the respondent used confidential information regarding properties, particularly two creeks that previously traversed his fishpond in Bulacan.
- The respondent was privy to the details of the fishpond and had access to the Transfer Certificate of Title (TCT) and its blueprint plan while he was serving as the complainant's attorney.
Respondent’s Defense
- The respondent filed a "Motion to Order Complainant to Specify His C