View full case

EUSTAQUIO v. NAVALES

FACTS:

Complainants spouses Lamberto V. Eustaquio and Gloria J. Eustaquio filed a complaint against Atty. Edgar R. Navales for failing to pay rent and vacate the apartment he is leasing. Complainants alleged that they are the owners of the apartment and they leased it to respondent. However, respondent violated the lease contract by failing to pay the monthly rentals amounting to P139,000.00 and refusing to vacate the premises despite repeated demands. The matter was brought to barangay conciliation where the parties reached an amicable settlement, wherein respondent promised to pay P131,000.00 and vacate the premises. However, respondent failed to fulfill his obligations under the settlement agreement, prompting complainants to file an ejectment case. Meanwhile, respondent was appointed as an Assistant City Public Prosecutor of Quezon City. The MeTC ruled in favor of the complainants in the ejectment case, ordering respondent to pay unpaid rentals, monthly rental payments, attorney's fees, and costs of suit. The Integrated Bar of the Philippines (IBP) found respondent administratively liable for violating the Code of Professional Responsibility and recommended a six-month suspension. The IBP Board of Governors adopted and approved the recommendation, and the Supreme Court issued a resolution meting out the same penalty. Respondent's suspension order became final and executory. However, respondent continued to act as an Assistant City Prosecutor, prompting the Office of the Court Administrator (OCA) to request for clarification from the MeTC. The MeTC issued a certification stating that respondent has been appearing before it since September 2014. The OBC recommended an additional six-month suspension for respondent for failing to comply with his original suspension. The sole issue for resolution is whether respondent should be held administratively liable.

ISSUES:

RULING:

PRINCIPLES:

  • A lawyer should exhibit honesty, integrity, and respect for the laws. (Violation of Rules 1.01 and 1.02, Canon 1 of the Code of Professional Responsibility).

  • Failure to fulfill obligations and evasion of payment of debts are considered as unwarranted obstinacy and may result in administrative liability.