FACTS:

The case involves a complaint for disbarment filed by Ma. Luisa Hadjula against Atty. Roceles F. Madianda. Hadjula alleged in her affidavit-complaint that she and Madianda used to be friends and sought legal advice from Madianda in 1998. However, Madianda refused to handle her case after personal secrets were disclosed and certain documents were produced. Hadjula claimed that their friendship soured after she filed criminal and disciplinary actions against Madianda. In retaliation, Madianda filed a counter-complaint against Hadjula and also initiated a disciplinary case against her. Hadjula sought the suspension and/or disbarment of Madianda for disclosing personal secrets and confidential information.

In Madianda's answer, she denied giving legal advice to Hadjula and denied the existence of a lawyer-client relationship between them. Madianda argued that the allegedly confidential information and documents were common knowledge in the Bureau of Fire Protection.

ISSUES:

1. Whether or not respondent Atty. Roceles F. Madianda violated Article 209 of the Revised Penal Code and Canon Nos. 15.02 and 21.02 of the Code of Professional Responsibility.

2. Whether or not there was a lawyer-client relationship between complainant Ma. Luisa Hadjula and respondent Atty. Roceles F. Madianda.

RULING:

1. No. The Supreme Court found that there was insufficient evidence to support the allegations against respondent. The Court noted that respondent denied giving legal advice to the complainant and stated that there was no lawyer-client relationship between them. Respondent also argued that the alleged confidential information disclosed by complainant was already a matter of common knowledge in the Bureau of Fire Protection. The Court emphasized that the burden of proof lies with the complainant in a disbarment case, and in this case, complainant failed to demonstrate any wrongdoing on the part of respondent.

2. No. The Supreme Court ruled that there was no lawyer-client relationship between complainant and respondent. Respondent denied having a lawyer-client relationship with complainant and maintained that she did not give any legal advice or handle any legal matter for complainant. The Court agreed with respondent's argument and concluded that there was no basis to establish the existence of a lawyer-client relationship.

PRINCIPLES:

• The burden of proof lies with the complainant in a disbarment case.

• To establish a lawyer-client relationship, it must be proven that there was an intent to seek legal advice, and the lawyer consented to give such advice.