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ATTY. LESTER R. NUIQUE v. ATTY. EDUARDO SEDILLO

FACTS:

In this case, Atty. Eduardo Sedillo is accused of violating the prohibition on representing conflicting interests, as alleged by Atty. Lester R. Nuique in a complaint for disbarment. Nuique claims that Sedillo represented conflicting interests by appearing as counsel for Estrelieta and her brother Manuel in a falsification complaint, even though he was still the counsel of Kiyoshi in another case.

In addition to the conflict of interest issue, Nuique also accuses Sedillo of using abusive language and showing disrespect towards the court. It is alleged that Sedillo used abusive language during court proceedings and displayed disrespectful behavior towards the court.

Furthermore, Nuique claims that Sedillo spread rumors against a colleague in the legal profession. The complaint specifically states that Sedillo engaged in spreading rumors that tarnished the reputation of a fellow lawyer.

These allegations and complaints were filed by Nuique with the Commission on Bar Discipline of the Integrated Bar of the Philippines against Atty. Eduardo Sedillo.

ISSUES:

  1. Whether the respondent should be administratively sanctioned based on the allegations in the Complaint.

  2. Whether the respondent violated the prohibition on representing conflicting interests as stated in Rule 15.03, Canon 15 of the Code of Professional Responsibility.

RULING:

  1. The Court agrees with the findings and recommendations of the Investigating Commissioner and the IBP Board of Governors. The respondent violated the prohibition on representation of conflicting interests. The respondent's representation of Estrelieta and Manuel against Kiyoshi, despite being the counsel of Kiyoshi and Estrelieta in another case, creates a suspicion of unfaithfulness or double-dealing in the performance of his duty towards his clients. The respondent should have advised Estrelieta and Manuel to engage the services of another lawyer.

  2. The Court finds the respondent guilty of misconduct for representing conflicting interests in violation of Rule 15.03, Canon 15 of the Code of Professional Responsibility. As a result, the respondent is suspended from the practice of law for a period of six (6) months.

PRINCIPLES:

  • Section 27, Rule 138 of the Rules of Court provides that a lawyer may be disbarred or suspended for gross misconduct, which includes any fault or deficiency in moral character, honesty, probity, or good demeanor.

  • Rule 15.03, Canon 15 of the Code of Professional Responsibility prohibits lawyers from representing conflicting interests without the written consent of all concerned after a full disclosure of the facts.

  • Conflict of interest arises when a lawyer's duty to one client requires them to oppose the interests of another client. It is a violation of the rule if a lawyer's argument for one client has to be opposed by the same lawyer in arguing for another client.

  • Lawyers are expected to keep their client's confidence inviolate and to avoid the appearance of treachery and double-dealing.

  • The prohibition against representing conflicting interests applies even if the cases involved are unrelated.

  • The nature or conditions of a lawyer's retainers with opposing clients can affect the lawyer's duty of undivided fidelity to each client.

  • The representation of opposing clients, even in unrelated cases, is deemed to invite suspicion of double-dealing and is not allowed.