A.C. No. 14062, April 02, 2025
Manuel H. Reyes, Complainant, vs. Atty. Diosdado C. Sebrio, Jr., Respondent.

FACTS

Complainant Manuel H. Reyes financed his friend Danilo Zialcita’s purchase of a property. Zialcita introduced respondent Atty. Diosdado C. Sebrio, Jr., who was hired on a contingency basis to facilitate the transfer and registration of the title. Reyes alleged that Atty. Sebrio induced his hiring by falsely representing personal connections with the Land Registration Authority (LRA) Administrator and the Register of Deeds of Quezon City, and by promising delivery of the title within six months. From January to April 2007, Reyes gave Atty. Sebrio various sums totaling PHP 870,000.00, as evidenced by signed receipts specifying the amounts were for related expenses and representation.
After six months with no results, Atty. Sebrio became uncommunicative. Reyes and Zialcita discovered that the LRA and Registry of Deeds had no knowledge of Atty. Sebrio. Furthermore, Atty. Sebrio borrowed an additional PHP 200,000.00 from Reyes in June 2007 but failed to repay it despite demands. In his defense, Atty. Sebrio admitted receiving the funds but claimed they were part of Reyes’s larger investment commitment. He denied making specific false representations, asserting he only mentioned having “friends” in the agencies, and argued that Reyes failed to provide the full financing needed for the project.

ISSUE

Whether Atty. Sebrio is administratively liable for serious misconduct.

RULING

Yes, Atty. Sebrio is guilty of gross misconduct warranting disbarment. The Court found clear and convincing evidence that he engaged in deceitful conduct. His defense was inconsistent and uncorroborated, while Reyes substantiated his claims with signed receipts and an affidavit from Zialcita. Atty. Sebrio’s false representations about his connections and capabilities to expedite the titling process constituted dishonesty and a deliberate attempt to secure money from the complainant. His subsequent evasion and failure to account for the funds or return them, coupled with his failure to repay a separate loan, demonstrated a pattern of fraudulent behavior.
This conduct violated the lawyer’s oath and the Code of Professional Responsibility, specifically Rule 1.01, which prohibits engaging in unlawful, dishonest, or deceitful conduct. The Court emphasized that a lawyer’s integrity must be beyond reproach. Atty. Sebrio’s actions betrayed the trust inherent in the attorney-client relationship and grossly undermined public confidence in the legal profession. Considering the gravity of the offense, the presence of aggravating circumstances (including a prior administrative case), and the absence of mitigating factors, the penalty of suspension was deemed insufficient. The Supreme Court modified the IBP’s recommendation and imposed the ultimate penalty of disbarment.