LORENZANA FOOD CORPORATION v. ATTY. FRANCISCO L. DARIA

FACTS:

The respondent lawyer in this case is facing administrative charges of negligence and betrayal of his former client's confidences. The charge of negligence stems from the respondent's handling of a labor case filed by an employee of Lorenzana Food Corporation (LFC), Violeta Hanopol, for illegal dismissal and other monetary claims. Respondent was hired as LFC's legal counsel in January 1981 and became its personnel manager six months later. Despite attempts to reach a settlement, the hearing for Hanopol's case was rescheduled multiple times due to the respondent's failure to appear or conflicting schedules. The Labor Arbiter eventually issued a decision in favor of Hanopol, which the respondent appealed, leading to the remand of the case for further proceedings.

In June 1984, the respondent expressed his intention to resign, and a new lawyer was hired to take his place. During subsequent hearings in Hanopol's case, no one appeared for the complainant, resulting in a motion to revive the earlier decision. Atty. Jose Loy, Jr. was hired as the new lawyer, and he opposed the motion. The Labor Arbiter eventually revived the earlier decision, and the case was again remanded for further proceedings upon appeal.

Regarding the charge of betrayal of client confidences, while the respondent was still connected with LFC, its general manager issued a memorandum to an employee, Roberto San Juan, requiring an explanation for alleged double liquidation and unliquidated cash advances. The respondent, as part of the executive committee, investigated San Juan and placed him under preventive suspension based on the seriousness of the charge.

ISSUES:

  1. Whether or not the respondent lawyer, Atty. Francisco L. Daria, was negligent in handling his client's case.

  2. Whether or not the respondent lawyer betrayed his former client's confidences.

RULING:

  1. The respondent lawyer was found to be negligent in handling his client's case. He failed to appear for scheduled hearings and did not submit a position paper, which led to the Labor Arbiter considering the case submitted for decision solely based on the complainant's evidence. The negligence resulted in a decision being rendered against the client without adequate representation.

  2. The respondent lawyer was found to have not betrayed his former client's confidences. The allegations of betrayal were based on the respondent's involvement in the investigation and suspension of an employee for unliquidated cash advances. However, the Court found that the actions taken by the respondent were part of his duties as a member of the executive committee and were within the scope of his authority as the client's legal counsel.

PRINCIPLES:

  • Lawyers have a duty to exercise reasonable care and skill in handling their client's cases. Neglecting to appear for scheduled hearings and failing to submit necessary papers may constitute negligence.

  • Lawyers have a duty to maintain the confidentiality of their clients and should not disclose information entrusted to them during the course of their professional relationship, unless authorized or required by law.