FACTS:

The case involves a disbarment proceeding filed by Rebecca J. Palm against Atty. Felipe Iledan, Jr. for breaching the attorney-client privilege and representing conflicting interests. Complainant is the President of Comtech Worldwide Solutions Philippines, Inc., a company engaged in computer software development. From February to November 2003, respondent served as Comtech's retained corporate counsel. During this period, complainant personally met with respondent to review corporate matters, including potential amendments to the corporate by-laws.

In a meeting on October 1, 2003, respondent suggested that Comtech amend its by-laws to allow teleconferencing for board members who were outside the Philippines. However, due to a close relationship between respondent and Elda Soledad, a former officer and director of Comtech suspected of unauthorized disbursements, Comtech terminated its retainer agreement with respondent in November 2003.

In a stockholders' meeting on January 10, 2004, respondent objected to the participation of board members through teleconferencing, citing the lack of amendment in the corporate by-laws. Subsequently, in March 2004, Comtech's new counsel sent a demand letter to Soledad, to which respondent replied on her behalf. In a complaint filed in July 2004, Comtech accused Soledad of estafa, and respondent appeared as her counsel during the proceedings.

In January 2005, complainant filed a disbarment complaint against respondent before the Integrated Bar of the Philippines (IBP). Respondent argued that he had no access to confidential or privileged records of Comtech and that he did not represent conflicting interests in representing Soledad. The IBP found respondent guilty of violating Canon 21 of the Code of Professional Responsibility and representing interests conflicting with that of his former client.

ISSUES:

1. Whether or not Atty. Felipe Iledan, Jr. violated Canon 21 of the Code of Professional Responsibility by revealing information obtained in the course of an attorney-client relationship.

2. Whether or not Atty. Felipe Iledan, Jr. represented an interest that conflicted with that of his former client.

RULING:

1. Atty. Felipe Iledan, Jr. violated Canon 21 of the Code of Professional Responsibility by revealing information obtained in the course of an attorney-client relationship. He made use of privileged information about the intended amendment to allow members of the Board of Directors who were outside the Philippines to participate in board meetings through teleconferencing when he objected to the participation of certain directors during a stockholders' meeting.

2. Atty. Felipe Iledan, Jr. represented an interest that conflicted with that of his former client. He appeared as counsel for Elda Soledad, who was being charged with estafa by Comtech, his former client.

PRINCIPLES:

• The duty of a lawyer to protect the confidences and secrets of his or her client is paramount. (Canon 21 of the Code of Professional Responsibility)

• A lawyer who has been retained or has represented a client should not represent an interest that conflicts with that of the former client. (Canon 15 of the Code of Professional Responsibility)