A.C. No. 4676. May 4, 2006. SPS. ANTONIO and NORMA SORIANO, Complainants, vs. ATTY. REYNALDO P. REYES, Respondent.
FACTS

Complainant spouses engaged the services of Atty. Reynaldo P. Reyes for two civil cases. The first, Civil Case No. 20-465-90, was filed in 1990 against Peninsula Development Bank. The second, Civil Case No. 22-674-94, was filed in 1994 against the Technology and Livelihood Resource Center. During the pendency of the second case, the complainants inquired about the status of the first case, and respondent assured them it was still ongoing. However, they later discovered that the first case had been dismissed as early as December 16, 1991, due to respondent’s failure to file a mandatory pre-trial brief. A motion for reconsideration was subsequently denied.
Regarding the second case, complainants also found it had been dismissed for failure to prosecute, though it was later reinstated upon the filing of a motion for reconsideration. Claiming gross negligence and damage, the complainants filed a disbarment case against respondent. The Integrated Bar of the Philippines (IBP) Commission on Bar Discipline found respondent liable and recommended disbarment, which the IBP Board of Governors adopted.

ISSUE

Whether respondent Atty. Reynaldo P. Reyes is administratively liable for gross negligence in handling his clients’ cases.

RULING

Yes, respondent is administratively liable. The Supreme Court found respondent guilty of gross negligence, violating Canons 17 and 18 of the Code of Professional Responsibility. Canon 17 mandates that a lawyer owes fidelity to his client’s cause, while Canon 18 requires a lawyer to serve his client with competence and diligence.
The Court’s legal logic is clear: an attorney’s failure to file a required pre-trial brief constitutes inexcusable negligence. This omission directly caused the dismissal of Civil Case No. 20-465-90, as the Rules of Court equate such failure to a failure to appear at pre-trial, warranting dismissal. Respondent’s claim of a strategy to arrange a settlement does not excuse this procedural lapse. Furthermore, his failure to promptly and truthfully inform his clients about the dismissal of their case for over three years, despite their inquiries, breached his duty to keep clients reasonably informed. This lack of communication compounded the prejudice to his clients.
While the Court agreed with the IBP’s finding of liability, it modified the penalty. Considering the negligence pertained to two cases and that this appeared to be respondent’s first offense, the Court deemed the recommended penalty of disbarment too severe. Applying precedents for similar negligence, the Court suspended respondent from the practice of law for one year, with a warning that a repetition would be dealt with more severely.