FACTS:

Complainant Elibena Cabiles filed an administrative complaint seeking the disbarment of Atty. Leandro Cedo for neglecting the two cases she referred to him. Elibena engaged the services of Atty. Cedo to handle an illegal dismissal case. However, Atty. Cedo failed to file a Reply for his clients despite being paid his appearance fee. As a result, the Labor Arbiter ruled against his clients and ordered them to pay backwages and other benefits to the complainant. Furthermore, Atty. Cedo instructed his clients to pick up the required Memorandum for appeal on the last day to file, resulting in their appeal being dismissed for non-perfection. Elibena also hired Atty. Cedo to file a criminal case for unjust vexation but he failed to file it promptly, leading to its dismissal. Atty. Cedo did not refute the allegation that he failed to indicate his MCLE compliance. The IBP found Atty. Cedo guilty of violating Canons 5, 17, and 18 of the Code of Professional Responsibility and recommended a two-year suspension, which was reduced to one year by the IBP Board of Governors. The Supreme Court adopted the finding of the IBP and agreed with the recommended penalty.

ISSUES:

1. Whether respondent lawyer violated Canons 5, 17, and 18 of the Code of Professional Responsibility.

2. Whether respondent lawyer's actions constitute neglect of his clients' cases.

RULING:

1. Yes, respondent lawyer violated Canons 5, 17, and 18 of the Code of Professional Responsibility.

2. Yes, respondent lawyer's actions constitute neglect of his clients' cases.

PRINCIPLES:

• Continuing legal education is mandated for IBP members to ensure that they stay updated with the law and maintain ethical standards in the practice of law. (Violation of Canon 5)

• Lawyers are expected to handle cases diligently and competently, and failure to do so may constitute neglect of client's cases. (Violation of Canons 17 and 18)