A.C. No. 10679. March 10, 2015 (Case Brief / Digest)

**Title:** PO1 Jose B. Caspe vs. Atty. Aquilino A. Mejica: A Case of Legal Ethics and Professional Conduct

**Facts:**
The controversy began when PO1 Jose B. Caspe filed a complaint for attempted murder against Antonio Rodriguez Jr., with Atty. Aquilino A. Mejica representing him as legal counsel. Later, Atty. Mejica switched sides and represented Rodriguez Jr. in his counter-affidavit against Caspe, sparking an allegation of conflict of interest by Caspe against Mejica. In response to Mejica’s alleged conflict of interest and subsequent threats against him, Caspe pursued separate suits for damages and disbarment against Mejica. One particular incident leading to the disbarment case involved a complaint filed by a barangay tanod, Gaduena, represented by Atty. Mejica, against Caspe for serious slander by deed. This action was perceived by Caspe as retaliatory, prompted by Mejica’s earlier threats.

Caspe’s complaint led to a series of IBP proceedings against Atty. Mejica, characterized by Mejica’s repeated failures to attend mandated conferences and respond to the complaints, culminating in the complaint being submitted for decision due to his non-appearance.

**Issues:**
1. Whether Atty. Mejica violated Rules 1.03, 1.04, and 10.01 of the Code of Professional Responsibility (CPR) by allegedly encouraging the filing of retaliatory suits against Caspe.
2. Whether Atty. Mejica failed to observe due process by not responding to the IBP’s notices and failing to attend scheduled conferences, thereby disrespecting the legal proceedings.

**Court’s Decision:**
The Court adopted the findings of the IBP but altered the penalty, imposing a two-year suspension on Atty. Mejica from the practice of law. The Court agreed with the IBP that Mejica violated Rules 1.03, 1.04, and 10.01 by harnessing a corrupt motive in aiding Gaduena to file cases against Caspe, attributing the actions to revenge. Additionally, Mejica’s refusal to participate in the IBP proceedings demonstrated a lack of respect for the proceedings and constituted a further violation of Canon 11 of the CPR, which mandates respect for legal processes and judicial authorities.

**Doctrine:**
This case reiterates the principles of legal ethics involving conflicts of interest, dedication to the truth, and respect for legal processes. It emphasizes the prohibition against lawyers from engaging in any corrupt motive encouraging litigation or causing delay in proceedings, as stipulated in Rules 1.03, 1.04, and 10.01 of the CPR. Additionally, it affirms the requirement for lawyers to observe and maintain respect for the courts, judicial officers, and the legal processes as directed by Canon 11 of the CPR.

**Class Notes:**
– **Conflict of Interest:** Lawyers must avoid representing conflicting interests in proceedings, illustrating fidelity to the client’s cause.
– **Retaliatory Litigation:** Engaging in or encouraging retaliatory litigation for personal vendettas violates CPR provisions on ethics and professionalism.
– **Respect for Legal Procedures:** Lawyers are expected to respect legal proceedings, including responding to notices and attending mandatory hearings, as mandated by Canon 11 of the CPR.
– **Penalty for Misconduct:** The case exemplifies the Supreme Court’s discretion in imposing disciplinary sanctions on lawyers who breach professional ethics, with repeated offenses potentially resulting in increased severity of penalties.

**Historical Background:**
The case underscores the ongoing efforts of the Philippine legal system to uphold the integrity and professionalism of its members. It serves as a reminder of the ethical obligations lawyers have towards their clients, the courts, and the legal profession. This disciplinary action reflects the judiciary’s commitment to enforcing ethical conduct within the bar, affirming the principle that the practice of law is a privilege contingent upon adherence to the highest standards of law and morality.


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