A.C. No. 10441. February 14, 2018. SUSAN T. DE LEON, Complainant, vs. ATTY. ANTONIO A. GERONIMO, Respondent.
FACTS

Complainant Susan T. De Leon engaged respondent Atty. Antonio A. Geronimo to represent her in a labor case. The Labor Arbiter initially dismissed the illegal dismissal complaints but ordered De Leon to pay financial assistance. Without informing De Leon, the employees appealed. The NLRC reversed the decision, ordering reinstatement and payment of over ₱7 Million. Atty. Geronimo prepared a cursory Motion for Reconsideration, prompting De Leon to file a supplemental motion herself. On March 1, 2006, De Leon discovered that Atty. Geronimo had received a denial of these motions in August 2005 but never informed her. When she inquired why he did not appeal to the Court of Appeals, he allegedly replied it did not matter as she had no money or properties. De Leon terminated his services and filed this disbarment complaint.
Atty. Geronimo defended himself by claiming De Leon had instructed him to surrender the case records in January 2005 so another lawyer could handle the Motion for Reconsideration, effectively relieving him. Despite this, he prepared and filed a motion for her without fee. He asserted he informed her of the NLRC’s denial and discussed the financial implications of a CA appeal, which De Leon declined due to lack of funds. He denied making derogatory statements, explaining his comments about her lack of assets were in the context of explaining enforceability of a judgment.

ISSUE

Whether Atty. Antonio A. Geronimo violated the Code of Professional Responsibility and the Lawyer’s Oath, warranting disciplinary action.

RULING

Yes, Atty. Geronimo is administratively liable. The Court affirmed the IBP’s finding but modified the penalty to a six-month suspension. The lawyer-client relationship is fiduciary, demanding diligence, competence, and candid communication. Atty. Geronimo breached these duties. His failure to promptly and formally inform De Leon of the adverse NLRC Resolution for nearly six months constituted gross negligence and a blatant disregard for his duty to keep the client reasonably informed. This failure deprived De Leon of the opportunity to timely pursue further remedies. His claim of being relieved of duty was untenable; a lawyer’s withdrawal from a case must be formal and approved by the court. His preparation of the Motion for Reconsideration after the alleged relief confirmed the ongoing representation.
The Court found his explanations regarding his remarks unconvincing and indicative of a lack of dedication to his client’s cause. His actions demonstrated indifference, violating Canons 17 and 18 of the CPR, which require a lawyer to serve a client with competence and diligence and to keep the client informed. The six-month suspension aligns with jurisprudence for similar gross negligence, such as failure to appear at hearings or file necessary briefs, which compromises client interests. The penalty serves to uphold the standards of the legal profession.