Alex Ong vs. Atty. Elpidio Unto, Adm. Case No.

2417, February 6, 2002

FACTS: This is a disbarment case filed by Alex Ong against Atty. Elpidio D. Unto, for
malpractice of law and conduct unbecoming of a lawyer. It is evident from the records
that he tried to coerce the complainant to comply with his letter-demand by threatening
to file various charges against the latter. When the complainant did not heed his
warning, he made good his threat and filed a string of criminal and administrative cases
against the complainant. They, however, did not have any bearing or connection to the
cause of his client, the records show that the respondent offered monetary rewards to
anyone who could provide him any information against the complainant just so he would
have leverage in his actions against the latter.
ISSUE: Whether or not Atty. Unto’s acts constitute malpractice.
HELD:
Yes. Canon 19 of the Code of Professional Responsibility mandates lawyers to
represent their clients with zeal but within the bounds of the law. Rule 19.01further
commands that a lawyer shall employ only fair and honest means to attain the lawful
objectives of his client and shall not present, participate, or threaten to present
unfounded criminal charges to obtain an improper advantage in any case or proceeding.

The Director of Lands vs. Ababa, Et Al., G.R. No. L-26096, February 27, 1979
FACTS: The adverse claimant, Atty. Alberto B. Fernandez was retained as counsel by
petitioner, Maximo Abarquez, in a civil case for the annulment of a contract of sale with
right of repurchase and for the recovery of the land which was the subject matter
thereof. The Court of First Instance of Cebu rendered a decision on May 29, 1961
adverse to the petitioner and so he appealed to the Court of Appeals. Litigating as a
pauper and engaging the services of his lawyer on a contingent basis, petitioner,
executed a document whereby he obliged himself to give to his lawyer one-half (1/2) of
whatever he might recover from Lots 5600 and 5602 should the appeal prosper.
Thereafter, the case was resolved in favor of Maximo Abarquez but he refused to
comply with his obligation and instead offered to sell the whole parcels of land to
petitioner-spouses Juan Larrazabal and Marta C. de Larrazabal. In order to protect his
interest, Atty. Fernandez filed an adverse claim for the half portion of the land, and it
was annotated in the certificate title of said land. Notwithstanding the annotation of the
adverse claim, petitioner-spouse Maximo Abarquez and Anastacia Cabigas conveyed
by deed of absolute sale two-thirds (2/3) of the lands to petitioner-spouses Juan
Larrazabal and Marta C. de Larrazabal. Petitioner spouses petitioned for the
cancellation of the adverse claim, contending that it is contrary to law and of the Canons
of Professional Ethics.
ISSUE: Whether or not the contract for a contingent fee, basis of the interest of Atty.
Fernandez, is prohibited by the Article 1491 of the New Civil Code and Canon 13 of the
Canons of Professional Ethics.
HELD: This contention is without merit. Article 1491 prohibits only the sale or
assignment between the lawyer and his client, of property which is the subject of
litigation. A contract for a contingent fee is not covered by Article 1491 because the
transfer or assignment of the property in litigation takes effect only after the finality of a
favorable judgment. In the instant case, the attorney's fees of Atty. Fernandez,
consisting of one-half (1/2) of whatever Maximo Abarquez might recover from his share
in the lots in question, is contingent upon the success of the appeal. Hence, the
payment of the attorney's fees, that is, the transfer or assignment of one-half (1/2) of the
property in litigation will take place only if the appeal prospers. Therefore, the transfer
actually takes effect after the finality of a favorable judgment rendered on appeal and
not during the pendency of the litigation involving the property in question.
Consequently, the contract for a contingent fee is not covered by Article 1491.
Petitioners her contend that a contract for a contingent fee violates the Canons of
Professional Ethics. This is likewise without merit. For while Canon 10 prohibits a lawyer
from purchasing ...any interest in the subject matter of the litigation which he is
conducting", Canon 13, on the other hand, allowed a reasonable contingent fee
contract, thus: "A contract for a contingent fee where sanctioned by law, should
be reasonable under all the circumstances of the case including the risk and
uncertainty of the compensation, but should always be subject to the supervision of a
court, as to its reasonableness. "Contracts of this nature are permitted because they
redound to the benefit of the poor client and the lawyer "especially in cases where
the client has meritorious cause of action, but no means with which to pay for legal
services unless he can, with the sanction of law, make a contract for a contingent fee to
be paid out of the proceeds of the litigation" (Francisco, Legal Ethics, p. 294 [1949],
citing Lipscomb vs. Adams 91 S.W. 1046, 1048 [1949]). Oftentimes, contingent fees
are the only means by which the poor and helpless can redress for injuries
sustained and have their rights vindicated. The one-half (½) interest of Atty. Fernandez
in the lots in question should therefore be respected. Indeed, he has a better right than
petitioner-spouses, Juan Larrazabal and Marta C. de Larrazabal. They purchased their
two-thirds (2/3) interest in the lots in question with the knowledge of the adverse
claim of Atty. Fernandez. The adverse claim was annotated on the old transfer
certificate of title and was later annotated on the new transfer certificate of title
issued to them. Having purchased the property with the knowledge of the adverse
claim, they are therefore in bad faith. Consequently, they are estopped from questioning
the validity of the adverse claim. WHEREFORE, THE DECISION OF THE LOWER
COURT DENYING THE PETITION FOR THE CANCELLATION OF THE ADVERSE
CLAIM SHOULD BE, AS IT IS HEREBY AFFIRMED, WITH COSTS
AGAINST PETITIONERAPPELLANTS JUAN LARRAZABAL AND MARTA C. DE
LARRAZABAL. SO, ORDERED.
 The Conjugal Partnership of the Spouses Vicente Cadavedo and Benita
Arcoy-Cadavedo, G.R. No. 173188, January 15, 2014
Facts: The Spouses Cadavedo acquired a homestead grant over a 230,765-square
meter parcel of land known as Lot 5415 (subject lot) located in Gumay, Piñan,
Zamboanga del Norte. They were issued Homestead Patent No. V-15414 on March 13,
1953and Original Certificate of Title No. P-376 on July 2, 1953.On April30, 1955, the
spouses Cadavedo sold the subject lot to the spouses Vicente Ames and Martha
Fernandez (the spouses Ames) Transfer Certificate of Title (TCT) No. T-4792 was
subsequently issued in the name of the spouses Ames. The present controversy arose
when the spouses Cadavedo filed an action before the RTC against the spouses Ames
for sum of money and/or voiding of contract of sale of homestead after the latter failed
to pay the balance of the purchase price. The spouses Cadavedo initially engaged the
services of Atty. Rosendo Bandal who, for health reasons, later withdrew from the case;
he was substituted by Atty. Lacaya. On February 24, 1969, Atty. Lacaya amended the
complaint to assert the nullity of the sale and the issuance of TCT No. T-4792 in the
names of the spouses Ames as gross violation of the public land law. The amended
complaint stated that the spouses Cadavedo hired Atty. Lacaya on a contingency fee
basis. The contingency fee stipulation specifically reads:10. That due to the above
circumstances, the plaintiffs were forced to hire a lawyer on contingent basis and if they
become the prevailing parties in the case at bar, they will pay the sum ofP2,000.00 for
attorney’s fees. Eventually Atty. Lacaya represented the Cadavedo spouses I two other
cases in connection with the subject lot. On appeal to the CA the appellate court
granted attorney’s fee consisting of one-half or 10.5383hectares of the subject lot to
Atty. Lacaya, instead of confirming the agreed contingent attorney’s fees of 2,000.00₱
Issue: Whether or not the award by the CA of attorney's fees is valid.
Held: No, The Supreme Court held that spouses Cadavedo and Atty. Lacaya agreed
on a contingent fee of 2,000.00 and not, as asserted by the latter, one-half of the
subject lot. The stipulation contained in the amended complaint filed by Atty. Lacaya
clearly stated that the spouses Cadavedo hired the former on a contingency basis; the
Spouses Cadavedo undertook to pay their lawyer 2,000.00 as attorney’s fees should
the case be decided in their favor. Granting ₱arguendo that the spouses Cadavedo and
Atty. Lacaya indeed entered into an oral contingent fee agreement securing to the latter
one-half of the subject lot, the agreement is void. The agreement is champertous and is
contrary to public policy. Any agreement by a lawyer to “conduct the litigation in his own
account, to pay the expenses thereof or to save his client therefrom and to receive as
his fee a portion of the proceeds of the judgment is obnoxious to the law.” The rule of
the profession that forbids a lawyer from contracting with his client for part of the thing in
litigation in exchange for conducting the case at the lawyer’s expense is designed to
prevent the lawyer from acquiring an interest between him and his client.
 Heirs of Juan de Dios Carlos vs. Linsangan, A.C. No. 11494, July 24, 2017
FACTS:
The parcel of land located in Alabang, Muntinlupa City and covered by Transfer
Certificate of Title (TCT) No. 139061 with an area of 12,331 square meters was
previously owned by the Spouses Felix and Felipa Carlos. Their son, Teofilo Carlos
(Teofilo), convinced them to transfer said title to his name with a promise to distribute
the same to his brothers and sisters. Teofilo delivered the owner's duplicate copy of the
title to his brother, Juan. However, Teofilo sold the entire property to Pedro Balbanero
(Pedro). Pedro, however, failed to pay the agreed installment payments.

Atty. Linsangan acted as counsel for their late father in several cases, one of which
involving the recovery of a parcel of land. Complainants alleged that Atty. Linsangan
forced them to sign pleadings and documents, sold the parcel of land in Alabang,
Muntinlupa City in cahoots with complainants' estranged mother, and evaded payment
of income taxes when he divided his share in the subject property as his supposed
attorney's fees to his wife and children.

ISSUE:
Whether or not respondent is guilty of violating his lawyer's oath.

RULING:
After a careful review of the record of the case, the Court finds that respondent
committed acts in violation of his oath as an attorney thereby warranting the Court's
exercise of its disciplinary power.

The practice of law is not a right but a privilege bestowed by the State upon
those who show that they possess, and continue to possess, the qualifications required
by law for the conferment of such privilege. Whether or not a lawyer is still entitled to
practice law may be resolved by a proceeding to suspend or disbar him, based on
conduct rendering him unfit to hold a license or to exercise the duties and
responsibilities of an attorney. The avowed purpose of suspending or disbarring an
attorney is not to punish the lawyer, but to remove from the profession a person whose
misconduct has proved him unfit to be entrusted with the duties and responsibilities
belonging to an office of an attorney, and thus to protect the public and those charged
with the administration of justice. The lawyer's oath is a source of obligations and its
violation is a ground for suspension, disbarment or other disciplinary action.

these acts are in direct contravention of Article 1491(5) of the Civil Code which forbids
lawyers from acquiring, by purchase or assignment, the property that has been the
subject of litigation in which they have taken part by virtue of their profession. While
Canon 10 of the old Canons of Professional Ethics, which states that " the lawyer
should not purchase any interests in the subject matter of the litigation which he is
conducting," is no longer reproduced in the new Code of Professional Responsibility
(CPR), such proscription still applies considering that Canon I of the CPR is clear in
requiring that "a lawyer shall uphold the Constitution, obey the laws of the land
and promote respect for law and legal process" and Rule 138, Sec. 3 which requires
every lawyer to take an oath to "obey the laws as well as the legal orders of the duly
constituted authorities therein." Here, the law transgressed by Atty. Linsangan is
Article 1491(5) of the Civil Code, in violation of his lawyer's oath.

Atty. Linsangan, at the guise of merely waiving portions of the subject property in favor
of his wife and children, actually divided his attorney's fee with persons who are not
licensed to practice law in contravention of Rule 9.02, Canon 9 of the CPR.

Another misconduct committed by Atty. Linsangan was his act of selling the entire
12,331 square meters property and making it appear that he was specifically authorized
to do so by complainants as well as by the other persons to whom portions of the
property had been previously adjudicated. However, a perusal of the supposed Special
Power of Attorney attached to the Deed of Absolute Sale, save for that executed by his
wife and children, only authorizes Atty. Linsangan to represent complainants in the
litigation of cases involving Juan's properties. Nothing in said Special Power of Attorney
authorizes Atty. Linsangan to sell the entire property including complainants' undivided
share therein.

Worse, Atty. Linsangan does not deny having received the downpayment for the
property from Helen. Atty. Linsangan does not also deny failing to give complainants'
share for the reason that he applied said payment as his share in the property. In so
doing, Atty. Linsangan determined all by himself that the downpayment accrues to him
and immediately appropriated the same, without the knowledge and consent of the
complainants. Such act constitutes a breach of his client's trust and a violation of Canon
16 of the CPR. Indeed, a lawyer is not entitled to unilaterally appropriate his client's
money for himself by the mere fact that the client owes him attorney’s fees. The failure
of an attorney to return the client's money upon demand gives rise to the presumption
that he has misappropriated it for his own use to the prejudice and violation of the
general morality, as well as of professional ethics; it also impairs public confidence in
the legal profession and deserves punishment. In short, a lawyer's unjustified
withholding of money belonging to his client, as in this case, warrants the imposition of
disciplinary action.

the relationship of attorney and client has consistently been treated as one of special
trust and confidence. An attorney must therefore exercise utmost good faith and
fairness in all his relationship with his client. Measured against this standard,
respondent's act clearly fell short and had, in fact, placed his personal interest above
that of his clients. Considering the foregoing violations of his lawyer's oath, Article
1491(5) of the Civil Code, Rule 9.02, Canon 9, and Canon 16 of the CPR, the Court
deems it appropriate to impose upon respondent the penalty of six (6) months
suspension from the practice of law.

WHEREFORE, we find Atty. Jaime S. Linsangan LIABLE for violations of his lawyer's
oath, Article 1491(5) of the Civil Code, Rule 9.02, Canon 9, and Canon 16 of the Code
of Professional Responsibility and he is hereby SUSPENDED from the practice of law
for SIX (6) months effective from the date of his receipt of this Decision. Let copies of
this Decision be circulated to all courts of the country for their information and guidance,
and spread in the personal record of Atty. Linsangan.

Pormento vs. Pontevedra, A.C. No. 5128, March 31, 2005

Facts: Elesio C. Pormento, Sr. charged Atty. Elias A. Pontevedra with malpractice.
Complainant claims that respondent, who was his lawyer in Civil Case No 1648,
deliberately failed to inform him of the dismissal of his counterclaim. Complainant
asserts that he only came to know of the existence of the order when the
adverse party foreclosed the mortgage executed over the land which is the subject
matter of the suit. Complainant also posited that in order to protect his rights, he was
forced to file a case for qualified theft against the relatives of the alleged new owner of
the said land. Respondent is the counsel of the accused in said case. Lastly,
complainant maintained that respondent is guilty of representing conflicting interests
when he acted as the counsel of complainant’s nephew in an ejectment case filed
by him while notarizing at the same time the Deed of Sale of the land which is the
subject matter of the case. On his reply, respondent claimed that within two days
upon his receipt of the order, he delivered the same to the complainant. As to his
representation of the persons against whom complainant filed criminal cases for
theft, respondent argues that he honestly believes that there exists no conflict
between his present and former clients’ interests. With respect to the ejectment case,
respondent admits that it was he who notarized the deed of sale of the land.
However, he contends that what is being contested in the said case is not the
ownership of the land but the ownership of the house built on the said land.
Issues: (1)Whether or not respondent failed to inform complainant regarding the
dismissal of the latter’s counterclaim.
(2)Whether or not respondent represented conflicting interests when he represented the
complainant’s nephew in an ejectment case while notarizing at the same time the
Deed of Sale of the land involved in the case.
(3)Whether or not respondent represented conflicting interests when he represented
the accused in the case for qualified theft filed by the complainant.
Ruling: The SC ruled in negative for the first two issues. Complainant failed to
present evidence to prove that respondent did not inform him of the dismissal of
his counterclaim. On the contrary, respondent presented a certification where
complainant’s daughter acknowledged receipt of the entire records of the civil case.
With respect to the second ground, the SC noted that the only established
participation respondent had with respect to the parcel of land purchased by
complainant, is that he was the one who notarized the deed of sale. On that basis
alone, it does not necessarily follow that respondent obtained any information from
complainant that can be used to the detriment of the latter in the ejectment case he
filed. However, the SC ruled in affirmative for the last issue. When respondent
was the counsel of complainant in Civil Case No. 1648, he became privy to the
documents and information that complainant possessed with respect to the said
parcel of land. Hence, whatever may be said as to whether or not respondent
utilized against complainant any information given to him in a professional
capacity, the mere fact of their previous relationship should have precluded
him from appearing as counsel for the opposing side. A lawyer is forbidden
from representing a subsequent client against a former client when the subject
matter of the present controversy is related, directly or indirectly, to the subject matter
of the previous litigation in which he appeared for the former client. The reason
for this is found in the relation of attorney and client, which is one of trust and
confidence of the highest degree.

Alcantara vs. De Vera, A.C. No. 5859, November 23, 2010

Facts: Rosario Mercado won in a civil case with Atty. Eduardo De Vera as her legal
counsel. Upon execution of the decision and collection of bank deposits for Mercado,
Atty. De Vera refused to turn over the proceeds, saying that the money was used to pay
court fees and the remaining are his as attorney’s fees.
Mercado filed a disbarment case against Atty. De Vera for infidelity in the custody and
handling client’s funds. The Integrated Bar of the Philippines sanctioned Atty. De Vera
with a suspension of practice for one (1) year. Following this, Atty. De Vera filed
baseless lawsuits against most of the members of the Mercado Family under different
jurisdictions. He also filed cases against IBP governors who recommended his
suspension.
Mercado contents that Atty. De Vera is exploiting their personal family problems just to
pursue unwarranted cases. She also alleged that Atty. De Vera is guilty of forum
shopping and harassment for the filing of baseless charges.

Atty. De Vera contends that he is only exhausting all the available legal remedies, and
that the charges filed against members of the Mercado family were done in good faith.
Issue: Whether or not Atty. De Vera violated the Code of Professional Responsibility by
instituting baseless and unwarranted suits that are only aimed to harass Mercado and
her family.

Held: Atty. De Vera was found guilty of violating the lawyer’s oath and the Code of
Professional Responsibility for raising unfounded lawsuits against the Mercado family
and several IBP board members who recommended his suspension.

Such act is deemed retaliatory and is unbecoming of a member of the bar who should
uphold the integrity, honesty and dignity of the legal profession. Atty. De Vera was
disbarred permanently from practice

Palacios vs. Amora, A.C. No. 11504, August 1, 2017

The Facts

The facts as found by the Integrated Bar of the Philippines, Board of Governors (IBP-
BOG), are as follows:

Complainant is the owner[-]developer of more or less 312 hectares of land estate

property located at Barangays San Vicente, San Miguel, Biluso and Lucsuhin,
Municipality of Silang, Province of Cavite ("property"). Said property was being
developed into a residential subdivision, community club house and two (2)
eighteen[-]hole, world-class championship golf courses (the "Riviera project"). In 1996,
complainant entered into purchase agreements with several investors in order to
finance its Riviera project. One of these investors was Philippine Golf Development and
Equipment, Inc. ("Phil Golf"). On 07 March 1996, Phil Golf paid the amount of Php54
Million for the purchase of 2% interest on the Riviera project consisting of developed
residential lots, Class "A" Common Shares, Class "B" Common Shares, and Class "C"
Common Shares of the Riviera Golf Club and Common Shares of the Riviera Golf
Sports and Country Club.

On 02 June 1997, complainant retained the services of respondent of the Amora and
Associates Law Offices to represent and act as its legal counsel in connection with the
Riviera project (Annex "C" to "C-5" of the complaint). Respondent's legal services under
the said agreement include the following: issuance of consolidated title(s) over the
project, issuance of individual titles for the resultant individual lots, issuance of license
to sell by the Housing and Land Use Regulatory Board, representation before the SEC,
and services concerning the untitled lots included in the project. For the said legal
services, respondent charged complainant the amount of Php6,500,000.00 for which he
was paid in three different checks (Annexes "D" to "D3" of the complaint).

On 10 May 1999, complainant entered into another engagement agreement with

respondent and the Amora Del Valle & Associates Law Offices for the registration of the
Riviera trademark with the Intellectual Property Office (Annex "E" of the complainant)
where respondent was paid in check in the amount of Php158,344.20 (Annex "F" of the
complaint).

On 14 March 2000, another contract for services was executed by complainant and
respondent for the latter to act as its counsel in the reclassification by the Sangguniang
Bayan of Silang, Cavite of complainant's agricultural lot to "residential commercial
and/or recreational use" in connection with its Riviera project (Annexes "G" to "G4" of
the complaint). Under this contract, respondent was hired to "act as counsel and
representative of AFP-RSBS before the Sangguniang Bayan of Silang, Cavite in all
matters relative to the reclassification of the subject properties from agricultural to non-
agricultural uses." On 21 March 2000, respondent furnished complainant a copy of
Resolution No. MI-007, S of 2000 of the Sangguniang Bayan of Silang dated 21
February 2000 ("resolution") approving the conversion and was paid the amount of
Php1.8M (Annex "H" of the complaint). Notably, the resolution was passed on 21
February 2000 or a month before the signing of the said 14 March 2000 contract.
Clearly, when [the] 14 March 2000 contract was signed by complainant and respondent,
there was already a resolution of the Sangguniang Bayan of Silang approving the
conversion of complainant's properties to residential/commercial. Clearly, the Php1.8M
demanded and received by respondent is not justifiable for the sole and simple reason
that respondent could not have performed any service under the 14 March 2000
contract considering that the result sought by the complainant (reclassification) has
been fulfilled and completed as early as 21 February 2000. Respondent, must therefore,
be ordered to return this amount to complainant.

On 06 November 2000, complainant entered into another contract for legal services with
respondent for which the latter was paid the amount of Php14,000,000.00 to secure
Certificate of Registration and License to Sell from the SEC (Annexes "I" to "I-5" of the
complaint). In addition, complainant further paid respondent the following checks as
professional fees in obtaining the Certificate of Registration and Permit to Offer
Securities for shares and other expenses: EPCIB Check No. 443124 dated 13 February
2003 in the amount of Php1,500,000.00, CENB Check No. 74001 dated 29 February
2000 in the amount of Php6,754.00, CENB Check No. 70291 dated 15 September 1999
in the amount Php261,305.00, and LBP Check No. 48691 dated 26 January 2001 in the
amount of Php221,970.00.

As complainant's legal counsel, respondent was privy to highly confidential information

regarding the Riviera project which included but was not limited to the corporate set-up,
actual breakdown of the shares of stock, financial records, purchase agreements and
swapping agreements with its investors. Respondent was also very familiar with the
Riviera project[,] having been hired to secure Certificate of Registration and License to
Sell with the HLURB and the registration of the shares of stock and license to sell of the
Riviera Golf Club, Inc. and Riviera Sports and Country Club, Inc. Respondent further
knew that complainant had valid titles to the properties of the Riviera project and was
also knowledgeable about complainant's transactions with Phil Golf.
After complainant terminated respondent's services as its legal counsel, respondent
became Phil Golfs representative and assignee. Respondent began pushing for the
swapping of Phil Golfs properties with that of complainant. Respondent sent swapping
proposals to his former client, herein complainant, this time in his capacity as Phil Golfs
representative and assignee. These proposals were rejected by complainant for being
grossly disadvantageous to the latter. After complainant's rejection of the said
proposals, respondent filed a case against its former client, herein complainant on
behalf of a subsequent client (Phil Golf) before the HLURB for alleged breach of
contract (Annex "R" of the complaint). In this HLURB case, respondent misrepresented
that Phil Golf is a duly organized and existing corporation under and by virtue of the
laws of the Philippines because it appears that Phil Golfs registration had been revoked
as early as 03 November 2003. Despite Phil Golfs revoked Certificate of Registration,
respondent further certified under oath that he is the duly authorized representative and
assignee of Phil Golf. Respondent, however, was not authorized to act for and on behalf
of said corporation because Phil Golfs corporate personality has ceased. The Director's
Certificate signed by Mr. Benito Santiago of Phil Golf dated 10 May 2007 allegedly
authorizing respondent as Phil Golfs representative and assignee was null and void
since the board had no authority to transact business with the public because of the
SEC's revocation of Phil Golfs Certificate of Registration.[2]
Due to the above actuations of respondent, complainant filed the instant action for
disbarment.

Issue

The singular issue for the consideration of this Court is whether Atty. Amora should be
held administratively liable based on the allegations on the Complaint.
The Court's Ruling

The Court modifies the findings of the IBP-BOG and the penalty imposed on the
respondent who violated the 21.01 and 21.02 of the Code of Professional
Responsibility.
Additionally, by causing the filing of the complaint before the HLURB, the IBP-BOG
correctly points out that respondent must have necessarily divulged to Phil Golf and
used information that he gathered while he was complainant's counsel in violation of
Rules 21.01 and 21.02 of the CPR, which state:

CANON 21 - A LAWYER SHALL PRESERVE THE CONFIDENCE AND SECRETS OF

HIS CLIENT EVEN AFTER THE ATTORNEY-CLIENT RELATION IS TERMINATED.

Rule 21.01 - A lawyer shall not reveal the confidences or secrets of his client except;

(a) When authorized by the client after acquainting him of the consequences of the
disclosure;

(b) When required by law;

(c) When necessary to collect his fees or to defend himself, his employees or
associates or by judicial action.

Rule 21.02 - A lawyer shall not, to the disadvantage of his client, use information
acquired in the course of employment, nor shall he use the same to his own advantage
or that of a third person, unless the client with full knowledge of the circumstances
consents thereto.
The IBP-BOG properly found thus:

Using confidential information which he secured from complainant while he was the
latter's counsel, respondent accused his former client of several violations. In the
process, respondent disclosed confidential information that he secured from
complainant thereby jeopardizing the latter's interest. As discussed below, respondent
violated his professional oath and the CPR.