G.R. No. 5854 , September 30, 2003
Nora E. Miwa vs. Atty. Rene O. Medina

FACTS

Complainant Nora E. Miwa engaged the services of respondent Atty. Rene O. Medina as her counsel in a civil case for quieting of title and recovery of possession. The trial court scheduled multiple pre-trial conferences, but none were held due to the non-appearance of Miwa and her counsel despite notices. The court eventually terminated the pre-trial. During the trial, when it was the defendant’s turn to present evidence, several postponements were sought by her counsel. The trial court fined the respondent and later deemed Miwa to have waived her right to present evidence due to non-appearance on a scheduled hearing date without prior motion for postponition.
Respondent filed a motion for reconsideration and a motion to withdraw as counsel, both of which were denied by the trial court. The court found his explanations unsatisfactory, noting that he had received the hearing notice well in advance but failed to act diligently, and that his claim of terminated attorney-client relationship was belied by his continued appearance on record. Consequently, a judgment was rendered against Miwa, leading to the loss of her property. Miwa then filed a disbarment complaint before the IBP, alleging gross negligence.

ISSUE

Whether or not Atty. Rene O. Medina should be held administratively liable for gross negligence in handling his client’s case.

RULING

Yes, Atty. Medina is administratively liable for gross negligence. The Supreme Court affirmed the findings and recommendation of the IBP Board of Governors. The Court emphasized that a lawyer’s duty to serve a client with competence and diligence is enshrined in the Code of Professional Responsibility. Canon 18 and Rule 18.03 specifically mandate that a lawyer shall not neglect a legal matter entrusted to him.
The Court found that respondent exhibited a pattern of neglect. He failed to ensure his client’s appearance at pre-trial conferences, sought last-minute postponements causing inconvenience, and missed a crucial hearing without a timely motion for postponement, resulting in his client being deemed to have waived her right to present evidence. His excuse of being preoccupied as a political campaign manager was unacceptable, as a lawyer must handle only as many cases as he can efficiently manage and must give paramount importance to court duties. His negligence directly contributed to his client losing her case and her property. Therefore, he violated his oath and his duties under Canons 10, 12, and 18. The Court suspended him from the practice of law for one month and imposed a fine of P2,000.00.