G.R. No.: A.C. No. 13998 (Formerly CBD Case No. 22-6799)
Date: August 13, 2025

Case Parties/Title: Marife C. Manongsong, Complainant, vs. Atty. Ariel M. Reyes, Respondent.

FACTS

Sometime in 2019, respondent Atty. Ariel M. Reyes approached complainant Marife C. Manongsong to borrow PHP 1 million for his law firm’s operational expenses. As security, Atty. Reyes issued two Metrobank checks for PHP 500,000.00 each. Manongsong granted the loan. The first check was successfully encashed as partial payment. However, the second check was dishonored by the bank for being drawn against a closed account. Manongsong demanded payment. Atty. Reyes repeatedly promised new payment dates but failed to settle the debt, compelling Manongsong to engage another lawyer who sent a demand letter to his office and residence in September 2022. Atty. Reyes did not respond and became unreachable. In his Answer to the administrative complaint before the IBP Commission on Bar Discipline, Atty. Reyes pleaded for understanding, citing financial devastation from a wrong personal economic decision aggravated by the pandemic. He subsequently failed to participate in the IBP proceedings by not submitting his conference brief, not appearing at the mandatory conference, and not filing his position paper. The IBP Investigating Commissioner found him guilty of gross misconduct and recommended a one-year suspension. The IBP Board of Governors modified this to a six-month suspension.

ISSUE

Whether respondent Atty. Ariel M. Reyes committed gross misconduct and should be held administratively liable for the issuance and dishonor of a worthless check.

RULING

Yes, the Supreme Court found Atty. Ariel M. Reyes guilty of gross misconduct. Lawyers are held to high standards of morality, honesty, and integrity. The issuance of a worthless check, which was dishonored for being drawn against a closed account (a violation of Batas Pambansa Blg. 22), coupled with reneging on promises to pay a substantial debt despite repeated demands, constitutes gross misconduct. This act shows a lack of personal honesty and good moral character, tarnishing the legal profession’s image. Gross misconduct is a serious offense punishable by disbarment, suspension for over six months, or a fine exceeding PHP 100,000.00. However, the Court considered mitigating circumstances under Canon VI, Section 38 of the Code of Professional Responsibility and Accountability (CPRA), including the respondent’s plea for consideration due to financial hardship exacerbated by the pandemic, which reflected a measure of remorse, and the fact that he had partially paid the loan (the first check cleared). Citing analogous leniency in past cases like Egger v. Atty. Duran, the Court found a six-month suspension from the practice of law to be the sufficient and appropriate penalty. Thus, the Court approved the modified recommendation of the IBP Board of Governors.