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PRUDENCIO B. PORTUGUESE v. ATTY. JERRY R. CENTRO

FACTS:

Complainant Prudencio B. Portuguese, Jr. (Portuguese) filed a complaint against Atty. Jerry R. Centro (Atty. Centro) for gross negligence, abandonment, and dereliction of duty. Atty. Centro was Portuguese's counsel in a civil case before the Regional Trial Court (RTC) of Surigao City. Portuguese alleged that Atty. Centro failed to inform him about the RTC's decision, did not file a pleading to appeal or question the decision, and failed to file a memorandum as he claimed. Portuguese also asserted that Atty. Centro failed to contest the motion for execution, did not notify him of the hearing on the motion, and did not inform him about the court's resolution granting the motion. Portuguese also mentioned that Atty. Centro is facing other administrative charges. The Integrated Bar of the Philippines found Atty. Centro guilty of neglecting his duties and recommended his suspension from the practice of law for three years. The Board of Governors of the IBP adopted the recommendations and imposed the three-year suspension.

ISSUES:

  1. Whether Atty. Jerry R. Centro is guilty of gross negligence, abandonment, and dereliction of duty as alleged by the complainant, Prudencio B. Portuguese, Jr.

  2. Whether Atty. Centro violated specific provisions of the Code of Professional Responsibility (CPR).

RULING:

  1. The Supreme Court found Atty. Jerry R. Centro guilty of gross negligence, abandonment, and dereliction of duty.

  2. Atty. Centro violated several provisions of the CPR, including Canon 11, Canon 17, Canon 18, Rule 12.03, Rule 18.03, and Rule 18.04.

PRINCIPLES:

  • Lawyer's Oath Imposes an obligation on lawyers to act with fidelity to their clients, courts, and to conduct themselves with competence and diligence.

  • Rule 12.03, Canon 11 (CPR) A lawyer should not allow extensions of time to lapse without filing necessary pleadings and should provide an explanation for any failure to do so.

  • Canon 17 (CPR) A lawyer owes fidelity to the cause of his client.

  • Canon 18 (CPR) A lawyer must serve his client with competence and diligence.

  • Rule 18.03 (CPR) Negligence in connection with a legal matter entrusted to a lawyer renders him liable.

  • Rule 18.04 (CPR) A lawyer must keep the client informed about the status of the case and respond within a reasonable time to client requests for information.

  • Disciplinary Actions A lawyer may be suspended or disbarred for violating the Lawyer's Oath or the CPR.

  • Administrative Proceedings Aim to preserve the purity of the legal profession and ensure honest administration of justice.