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WILFREDO ANGLO v. ATTY. JOSE MA. V. VALENCIA

FACTS:

The complainant engaged the services of the law firm Valencia Ciocon Dabao Valencia De La Paz Dionela Pandan Rubica Law Office (law firm) to handle two consolidated labor cases in which he was a respondent. Atty. Dionela, a partner in the law firm, was assigned to represent the complainant in these cases. The labor cases were concluded on June 5, 2008. Subsequently, FEVE Farms Agricultural Corporation (FEVE Farms) filed a criminal case for qualified theft against the complainant and his wife. The law firm represented FEVE Farms in this case. The complainant initiated a disbarment case against the respondents, claiming that they violated the rule on conflict of interest under the Code of Professional Responsibility (CPR). The respondents argued that there were certain "arrangements" within their law firm and that the labor cases were exclusively handled by Atty. Dionela, while the qualified theft case was assigned to Atty. Penalosa, who was unaware of the complainant's labor cases. The Integrated Bar of the Philippines (IBP) initially found the respondents guilty of violating the rule on conflict of interest and recommended a reprimand, but the IBP Board of Governors modified the penalty to dismissal with a warning. After the respondents filed a motion for reconsideration, the IBP Board of Governors reprimanded them, dismissed the case against Atty. Dabao due to his demise, and suspended Atty. Dionela from practicing law for one year. The primary issue in this case revolves around whether or not the respondents are guilty of representing conflicting interests in contravention of the CPR.

ISSUES:

RULING:

PRINCIPLES:

  • Rule 15.03 of the Code of Professional Responsibility prohibits a lawyer from representing conflicting interests without the written consent of all parties involved given after a full disclosure of the facts.

  • The termination of the attorney-client relationship does not justify a lawyer representing an interest adverse or in conflict with that of the former client.

  • Canon 21 of the CPR mandates a lawyer to preserve the confidences and secrets of the client even after the attorney-client relationship is terminated.