A.C. No. 9906. July 29, 2013 (Case Brief / Digest)

**Title:** Atty. Lester R. Nuique vs. Atty. Eduardo Sedillo (Disbarment Case for Conflict of Interest)

In 1992, Atty. Eduardo Sedillo began representing spouses Kiyoshi Kimura and Estrelieta Patrimonio-Kimura in a recovery of overpayment case against Carlos Amasula, Jr., conducted through Estrelieta’s brother, Manuel Patrimonio. Despite a favorable trial court decision, the case was on appeal as of the complaint filing. Sedillo’s representation continued until Kiyoshi terminated his services in July 2007.

A conflict arose when Kiyoshi and Estrelieta’s marriage hit a snag, leading to allegations of Estrelieta and Manuel falsifying Kiyoshi’s signature for a loan, secured against Kiyoshi’s property. Consequently, Kiyoshi, represented by Atty. Lester R. Nuique, filed a falsification complaint against Estrelieta and Manuel in November 2006, whom Sedillo then represented, marking the inception of the conflict of interest.

Subsequent legal battles ensued, including a habeas corpus case filed by Estrelieta claiming Kiyoshi was detained against his will which was dismissed after Kiyoshi testified otherwise. Sedillo’s disrespectful court demeanor and rumor spreading against Nuique were additional complaint points.

Atty. Nuique formally lodged a disbarment complaint against Sedillo to the Integrated Bar of the Philippines (IBP), accusing him of representing conflicting interests, disrespect to the court, and maligning a fellow lawyer. The IBP and, eventually, the Supreme Court, delved into these allegations, scrutinizing Sedillo’s professional conduct.

1. Whether Sedillo represented conflicting interests by concurrently representing Kiyoshi and then Estrelieta and Manuel in interconnected legal matters.
2. Whether Sedillo’s conduct towards the court and Nuique constituted professional misconduct.

**Court’s Decision:**
– **Representing Conflicting Interests:** The Supreme Court found Sedillo guilty of violating Rule 15.03, Canon 15 of the Code of Professional Responsibility due to his concurrent representation of clients with opposing legal interests. This conflict was clear as Sedillo represented Estrelieta and Manuel against Kiyoshi while still listed as the counsel for Kiyoshi in another case.

– **Disrespect to the Court and Maligning Another Lawyer:** While the IBP Investigating Commissioner did not find Sedillo guilty of disrespect to the court or maligning Nuique, the primary focus remained on Sedillo’s conflicting representation.

Sedillo was suspended from the practice of law for six (6) months, with a stern warning against similar future misconduct.

The prohibition against representing conflicting interests outlined in Rule 15.03, Canon 15 of the Code of Professional Responsibility was central, emphasizing a lawyer’s duty to uphold unwavering fidelity and loyalty, avoiding the appearance of double-dealing.

**Class Notes:**
– **Essential Elements of Conflict of Interest:** Representing opposing interests without written consent after full disclosure, even in unrelated cases, signifies a breach of ethical conduct.
– **Application:** Lawyers must ensure absolute devotion to their client’s cause, refraining from any representation or action that might conflict with this duty or insinuate double-dealing.
– **Citations:** “Rule 15.03 – A lawyer shall not represent conflicting interests except by written consent of all concerned given after a full disclosure of the facts.”

**Historical Background:**
This case underscores the Philippine legal profession’s stringent adherence to ethical standards, especially concerning client representation. It reflects the Supreme Court’s commitment to maintaining integrity and public trust in legal practice, providing a cautionary note to all lawyers about the paramount importance of loyalty and the detrimental impact of conflicting interests on the judiciary’s fairness and the broader legal system.


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