FACTS:
Manuel Enrique and Manuel Jose Zalamea sought the advice of Atty. Rodolfo de Guzman regarding their ailing mother's properties. After their mother's death, De Guzman prepared a letter for the transfer of one of the properties to the Merlinda Holding Corporation and notarized the incorporation papers of said corporation. In 2001, the Zalamea brothers established EMZEE FOODS INC., with De Guzman providing the capital and operational funds. In 2002, Manuel Enrique informed De Guzman about another property owned by their relatives and suggested the reacquisition of said property from Banco de Oro (BDO). De Guzman negotiated with BDO and secured a deal for the property. The Zalamea brothers filed a disbarment case against De Guzman for allegedly buying a client's property which was subject to litigation. The IBP recommended the dismissal of the complaint, which was later approved by the IBP Board of Governors.
ISSUES:
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Whether Atty. Rodolfo P. de Guzman, Jr. violated the Lawyer's Oath and the Code of Professional Responsibility by acquiring the property of his clients.
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Whether Atty. Rodolfo P. de Guzman, Jr. should be disbarred for his actions.
RULING:
- The complaint against Atty. Rodolfo P. de Guzman, Jr. is dismissed for lack of merit. The Integrated Bar of the Philippines (IBP) Board of Governors found that the complaint against Atty. De Guzman was baseless and unsupported by evidence.
PRINCIPLES:
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Lawyers have a duty to act with utmost fidelity and loyalty to their clients. They must not acquire the property of their clients unless there is a clear agreement or consent from the clients.
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Disbarment can only be imposed upon lawyers for gross misconduct that shows their unfitness to continue as officers of the court.