GR 452; (March, 1905) (Digest)
G.R. No. 452 : March 18, 1905
IN THE MATTER OF JOSE ROBLES LAHESA
FACTS:
Jose Robles Lahesa, a lawyer, was appointed by the Supreme Court as counsel de oficio (court-assigned counsel) for indigent appellants in two criminal cases: (1) for the appellants in United States vs. Julian Tulagan et al. on February 5, 1904, and (2) for the appellant in United States vs. Julio Liuag on August 12, 1904. In both cases, the appellants had been convicted of serious crimes and sentenced to long terms of imprisonment. Subsequently, the Solicitor-General moved to dismiss the appeal in the first case for abandonment, and the Court, on its own motion, issued a rule for Lahesa to show cause why the appeal in the second case should not be dismissed and why he should not be disciplined for grave neglect of duty. At the hearing, a representative for Lahesa informed the Court that Lahesa could not appear personally, offered no opposition to the dismissal of the appeals, and stated that Lahesa took no action because he believed “there was no defense to be made on behalf of any of the defendants.” The Court found that Lahesa had taken no action whatsoever in either case for over a year and over six months, respectively, since his appointments.
ISSUE:
Whether Atty. Jose Robles Lahesa should be held liable and subjected to disciplinary punishment for his failure to perform his duties as court-assigned counsel for indigent appellants.
RULING:
Yes. The Supreme Court found Atty. Jose Robles Lahesa guilty of grave negligence in the performance of his duties as counsel and as an officer of the court. The Court emphasized that it must exact the most scrupulous performance of official duties from its officers, especially when negligence results in delays in criminal appeals and the prolonged detention of accused persons. The Court rejected Lahesa’s stated reason for inactionthat he believed there was no defenseas unacceptable, as it is the duty of assigned counsel to diligently review the record and present any available arguments on behalf of the client. As a disciplinary measure, the Court imposed upon Lahesa a fine of two hundred pesos (P200), Philippine currency, payable to the Clerk of Court within ten days from notice. The appeals in the mentioned cases were subject to dismissal on the grounds of abandonment.