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Dongga-as vs.

Atty Cruz-
Angeles
Reporter: Karl Lois C. Pagaran LLB3

Violation of Rule 18.03, Canon 18; Rule 16.01 and


16.03, Canon 16; Rule 1.01, Canon 1 of the
Professional Code of Responsibility
FACTS OF THE CASE

Cleo B. Dongga-as engaged the law firm of Atty. Rose Beatrix Cruz-Angele, Atty.
Wylie M. Paler, and Atty. Angeles Grandea of the Angeles, Grandea & Paler Law
Office to handle the annulment of his marriage with his wife Mutya. In their
meeting, he was told that the case would cost him P300,000.00, with the first
P100,000.00 payable immediately and the remaining payable after the final
hearing.
Dongga-as constantly followed-up his case, however, the respondents could not
present any petition and instead offered excuses for the delay, such as, the
petition could not be filed since they have yet to talk to the judge who they
insinuated will probably resolve their petition.
The respondents sent a text message to Dongga-as, informing him that the NSO
bore no record of his marriage. However, upon his independent verification
through his friend, he discovered that the records of his marriage in the Civil
Registrar were intact, and that the alleged absence of such records was a mere
ruse to cover up the delay in the filing of the petition. Dongga-as got frustrated, so
he went to respondents law office to terminate their engagement and to demand
for a refund of the aggregate amount of P350,000.00 he earlier paid them.
ISSUE & RULING OF THE
CASE

ISSUE:
Whether or not the respondents can be
held liable for violating the Code of
Professional Responsibility.

RULING:
Yes. For violation of Rule 18.03, Canon 18;
Rule 16.01 and 16.03, Canon 16; Rule
1.01, Canon 1 of the Professional Code of
Responsibility.
ANGELITO RAMISCAL
and MERCEDES
ORZAME, vs. ATTY.
EDGAR S. ORRO.

R E P O RT E R : Te r e n c e L . Va l d e h u e z a

Violation of Canon 17, and Rules 18.03 and 18.04


of Canon 18 of the Professional Code of
Responsibility
FACTS OF THE CASE

Angelito Ramiscal and Mercedes Orzame were engaged in the legal services of Atty. Edgar
S. Orro to handle a case in which they were the defendants seeking the declaration of the
nullity of a land title. Upon receiving the P 10,000.00 acceptance fee, Atty. Orro handled
the case; it reached the RTC and was decided in their favor. The plaintiffs appealed the
case to the CA and filed their appellants brief. Upon the receipt thereof, Atty. Orro
requested from the Spouses an additional 30,000.00; the Spouses obliged. Later on, the
RTC decision was reversed by CA; Atty. Orro failed to inform the Spouses on the said
decision in which the latter only learned from their neighbors. They tried to communicate
with Atty. Orro but their efforts ended in vain. When they have finally contacted him, Atty.
Orro asked them an additional P7,000.00 for him to file a MR, albeit such motion would
already be belated. Even so, the Spouses paid him. To their dismay, they discovered that
Atty. Orro did not filed the MR and the decision had already attained finality.
The Spouses filed an administrative complaint against Atty. Orro; the Court referred the
complaint to IBP. Despite several notices, the both parties failed to appear the scheduled
mandatory conferences set by IBP nor submitted their evidences. The IBP Commissioner
rendered his findings to the effect that Atty. Orro violated the Code of the Professional
Responsibility, and recommended a one-year suspension. IBP Board of Governors adopted
the report of the IBP Commissioner but modified his recommendation of increasing the
penalty of suspension for two years.
ISSUE & RULING OF THE
CASE

ISSUE:
Whether or not Atty. Orro did not
competently and diligently discharge his
duties as the lawyer of the Spouses
Ramiscals.
RULING:
Yes. For violation of Rule 18.03, Canon 17;
and Rules 18.03 and 18.04, Canon 18 of
the Professional Code of Responsibility.