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207) Paz v. Sanchez AC No.

6125, 19 September 2006 (Caro)

Complainant: Simon D. Paz
Respondent: Atty. Pepito A. Sanchez
Canon 15 representing conflicting interests

Paz filed a disbarment complaint against Sanchez for representing

conflicting interests and violating the lawyers oath
In 1995, Paz and his partners engaged the services of Sanchez to:
o assist in the purchase and documentation of several parcels of
land from tenant-farmers in Pampanga
o defend Pazs claim on the above properties against one George
Lizares claim
Paz claimed he is guilty of conflict of interest because of the following:
o In 2000, allegedly after Sanchezs contract with Paz ended,
Sanchez filed a complaint before the Dept of Agrarian Reform
Board (DARAB) for one Isidro Dizon to annul a TCT in the
name of Paz and his partners when in fact, Dizons property was
among those he purchased with Sanchezs assistance
o (not that important) In 2003, Sanchez, despite knowledge of
Pazs pending petition for review of judgment in the DARAB
case, filed a civil case in the RTC against Paz for annulment of
In his comment, Sanchez stated:
o that he had been representing the tenant-farmers, including
Dizon in their DARAB cases since 1978.

That Paz and his partners indeed expressed interest in acquiring

Dizons property and that he represented them because they did
not get a lawyer of their own and allowed him to represent them
IBP found respondent guilty of violating the prohibition against
representing conflicting interests and recommended 1yr suspension

Issue: W/N Sanchez is guilty of representing conflicting interests?

Held: YES. Rule 15.03 of CPR: "a lawyer shall not represent conflicting interests
except by written consent of all concerned given after full disclosure of the facts."
Lawyers are deemed to represent conflicting interests when, in behalf of one
client, it is their duty to contend for that which duty to another client requires them
to oppose. The proscription against representation of conflicting interest applies to
a situation where the opposing parties are present clients in the same action or in
an unrelated action.
Sanchez admitted that when he filed the DARAB case for Dizon against Paz, both
were clients of Sanchez at that time. He did not specifically deny that he
represented conflicting interests. He merely attempted to justify his acts by stating
that he felt it was his duty and responsibility to file the case. However, good
faith and honest intentions do not excuse the violation of this prohibition. He
should have inhibited himself from representing Dizon against Paz in the DARAB
and RTC case