A.C. No. 11173, June 11, 2018
Re: CA-G.R. CV No. 96282 (Spouses Bayani and Myrna M. Partoza vs. Lilia B. Montano and Amelia Solomon), Complainant vs. Atty. Claro Jordan M. Santamaria, Respondent

FACTS

The case originated from a civil action for nullity of a mortgage and reconveyance filed by spouses Bayani and Myrna Partoza. After the Regional Trial Court dismissed their case, their counsel of record, Atty. Samson Villanueva, filed a notice of appeal. Atty. Villanueva later withdrew his appearance, with the conformity of the appellants’ attorney-in-fact, Honnie Partoza. Subsequently, respondent Atty. Claro Jordan M. Santamaria filed an Appellant’s Brief on behalf of the spouses.
The Court of Appeals (CA) issued a resolution directing Atty. Villanueva to submit proof of Honnie Partoza’s authority and his conformity to the withdrawal. Simultaneously, the CA ordered Atty. Santamaria to formally enter his appearance, submit his clients’ written conformity, and furnish a copy of the assailed RTC decision. Atty. Santamaria ignored this and several subsequent resolutions from the CA dated March 20, 2012, September 5, 2012, and October 25, 2012, which reiterated the directives and ultimately cited him in contempt with a fine. His continued inaction led the CA to refer his conduct to the Integrated Bar of the Philippines (IBP) for disciplinary action.

ISSUE

Whether Atty. Claro Jordan M. Santamaria should be held administratively liable for his repeated failure to comply with the lawful directives of the Court of Appeals.

RULING

Yes, Atty. Santamaria is administratively liable. The Supreme Court suspended him from the practice of law for six months. The legal logic is anchored on a lawyer’s fundamental duty to uphold the authority of the courts and respect judicial processes. Canon 11 of the Code of Professional Responsibility mandates that a lawyer shall observe and maintain respect due to the courts. By willfully and repeatedly ignoring multiple resolutions and orders from the CA, Atty. Santamaria exhibited disobedience to lawful court directives, which constitutes a violation of this duty.
The Court rejected his defenses, including his claim of lacking personality to represent the clients and his belief that the prior counsel should have handled the compliances. Once he filed the Appellant’s Brief, he assumed responsibility for the case and was duty-bound to comply with all court orders pertaining to his representation. His obstinate refusal, despite clear and repeated directives, demonstrated a recalcitrant character and disrespect for judicial authority, which undermines the administration of justice. The penalty of six months suspension was deemed commensurate, considering he disregarded five CA resolutions, as opposed to more severe penalties in cases involving a greater number of ignored orders. The Court sternly warned that a repetition would be dealt with more severely.