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HEIRS OF LATE SPS. JUSTICE v. ATTY. RONALD L. BRILLANTES

## FACTS:

The complainants, heirs of Justice Samuel F. Reyes and Mrs. Antonia C. Reyes, filed a complaint for quieting of title against the Spouses Divina before the RTC of Cauayan City, Isabela. The Spouses Divina filed a motion to dismiss, but it was denied. Despite the denial, they failed to file an answer to the complaint within the period allowed by the Rules of Court. The RTC declared them in default and allowed the Estate to present its evidence ex-parte. The Spouses Divina filed a certiorari petition with the Court of Appeals, but it was dismissed for lack of merit. The RTC rendered a decision in favor of the Estate, which was affirmed by the CA. The decision became final and executory. The Estate moved for the execution of the CA decision. Meanwhile, Spouses Divina engaged the services of Atty. Brillantes and filed a petition for annulment of judgment with the CA. The CA denied the annulment petition. Judge Reyes filed a disbarment complaint against Atty. Brillantes, alleging that he violated the rule on forum shopping, the Lawyer's Oath, and the Code of Professional Responsibility (CPR). The disbarment complaint was referred to the Integrated Bar of the Philippines (IBP) for investigation. The IBP found Atty. Brillantes guilty and recommended a two-month suspension. The IBP Board of Governors adopted the recommendation but increased the period of suspension to three months. Judge Reyes filed a motion for reconsideration, seeking disbarment. The IBP Board of Governors increased the recommended penalty to one year of suspension. Atty. Brillantes filed a motion for reconsideration, and the IBP Board of Governors reduced the period of suspension to six months. The issue is whether Atty. Brillantes should be held administratively liable for his actions.

ISSUES

The main issue presented for the Court's resolution is whether Atty. Ronald L. Brillantes should be held administratively liable for his actions.

RULING

The Court finds Atty. Ronald L. Brillantes guilty of violating the rule on forum shopping, the Lawyer's Oath, and Rule 10.01, Canon 10, Rules 12.02 and 12.04, Canon 12, and Rules 18.02 and 18.03, Canon 18 of the Code of Professional Responsibility. Consequently, Atty. Brillantes is suspended from the practice of law for a period of six (6) months. The Court concurs with the findings and recommendation of the IBP. Atty. Brillantes' actions of neglect and misrepresentation in his legal practice have rendered him administratively liable. His failure to competently handle his clients' legal matters, reliance on inaccurate client information, violation of codes on candor and forum shopping, and the resulting damage to the opposing parties lead to this suspension. The circumstances of his first infraction and the socio-economic impact of the Coronavirus Disease 2019 pandemic led to the decision not to impose a harsher penalty.

PRINCIPLES

  1. Duty of Competence and Diligence (Canon 18 CPR): A lawyer is obligated to serve his client with competence and diligence. Inadequate preparation or negligence in legal matters can render a lawyer administratively liable.

  2. Candor, Fairness, and Good Faith to the Court (Canon 10 CPR): A lawyer owes the duty of candor, fairness, and good faith to the court and should not engage in or consent to any falsehood.

  3. Prohibition Against Forum Shopping (Canon 12 CPR): A lawyer should not file multiple actions arising from the same cause or otherwise engage in actions intended to delay judicial processes or misuse court procedures.

  4. Responsibility in Handling Client Information: A lawyer must not blindly trust client representations but should verify such information, especially when it forms the basis of court submissions.

  5. Penalty Proportional to Infraction: The imposition of penalties, like suspension, must consider the severity of the infraction, past conduct, and existing extraneous circumstances such as socio-economic impacts.