G.R. No. A.C. No. 9594. April 05, 2022
THE HEIRS OF THE LATE SPOUSES JUSTICE AND MRS. SAMUEL F. REYES, HEREIN REPRESENTED BY JUDGE ANTONIO C. REYES, COMPLAINANTS, VS. ATTY. RONALD L. BRILLANTES, RESPONDENT.

FACTS

The complainants, heirs of the late Spouses Reyes, represented by Judge Antonio C. Reyes, filed a disbarment complaint against Atty. Ronald L. Brillantes for alleged violation of the rule on forum shopping, the Lawyer’s Oath, and the Code of Professional Responsibility (CPR). The complaint stemmed from Atty. Brillantes’s actions in a civil case for quieting of title filed by the Estate of the late spouses against the Spouses Divina. The RTC ruled in favor of the Estate, a decision which was affirmed by the CA and became final and executory on February 16, 2010. The Estate moved for execution, which the RTC granted. Subsequently, on August 9, 2011, Spouses Divina engaged Atty. Brillantes. On September 29, 2011, Atty. Brillantes filed a Petition for Annulment of Judgment with the CA, arguing his clients belatedly received the RTC Decision on August 19, 2011, preventing a timely appeal. The CA denied and dismissed the petition. In the disbarment complaint, Judge Reyes alleged that by filing the Annulment Petition, Atty. Brillantes committed a falsehood, as the Spouses Divina had actually received the RTC Decision on November 27, 2007, and he should have known this as he attached copies of the RTC Decision and the subsequent CA Resolution to his petition. Atty. Brillantes countered that he relied solely on his clients’ representations and the documents they provided, and was not informed that an appeal had already been resolved.

ISSUE

Whether Atty. Brillantes should be held administratively liable for his actions.

RULING

Yes, Atty. Brillantes is administratively liable. The Court concurred with the IBP’s finding that Atty. Brillantes violated his duties under the CPR. The IBP found that Atty. Brillantes failed to exercise due diligence by relying solely on his clients’ interview and representations without personally verifying the status of the case or retrieving pertinent documents from the trial court. This failure constituted gross negligence and a violation of Rules 18.02 and 18.03, Canon 18 of the CPR, which require a lawyer to handle legal matters with adequate preparation and not to neglect a matter entrusted to him. His acts of preparing and filing the Annulment Petition without proper verification amounted to gross negligence, misled the court, and caused undue delay. While the IBP Board of Governors initially recommended a one-year suspension, and later reduced it to six months, the Court adopted the final IBP recommendation. Atty. Brillantes was suspended from the practice of law for a period of six (6) months.