JOSEPHINE L. OROLA v. ATTY. JOSEPH ADOR RAMOS

FACTS:

Complainants are the children of the late Trinidad Laserna-Orola, married to Emilio Q. Orola. Another complainant, Karen Orola, is the daughter of Maricar Alba-Orola and Antonio L. Orola, who is deceased and the brother of the aforementioned complainants. The settlement of Trinidad's estate is pending before the Regional Trial Court (RTC) and the parties were represented by different counsels. Respondent entered his appearance as a collaborating counsel for Emilio, who sought the appointment as administrator of Trinidad's estate. Complainants filed a disbarment complaint against respondent for violation of Code of Professional Responsibility and Rules of Court. They claimed that respondent violated the Code by representing conflicting interests and breached the trust and confidence reposed upon him by his clients. Respondent argued that he never represented the heirs of Trinidad or Antonio, but only temporarily appeared for Maricar upon her request. He obtained Maricar's permission to withdraw from the case and consulted her before representing Emilio. The Integrated Bar of the Philippines (IBP) found respondent guilty of representing conflicting interests with respect to Karen, but not the other complainants. The IBP recommended a penalty of six months suspension from the practice of law. Respondent's motion for reconsideration was denied. The issue before the Court is whether respondent is guilty of representing conflicting interests in violation of the Code.

ISSUES:

RULING:

PRINCIPLES:

  • Rule 15.03, Canon 15 of the Code of Professional Responsibility: A lawyer shall not represent conflicting interests except by written consent of all concerned given after a full disclosure of the facts.

  • Section 20(e), Rule 138 of the Rules of Court: It is the duty of an attorney "to maintain inviolate the confidence, and at every peril to himself, to preserve the secrets of his client."