Professional Documents
Culture Documents
Sergio Angeles
A.C. No. 2519. August 29, 2000
Facts: Atty. Sergio Angeles was the legal counsel of Teodoro Rivera and 2 others in a civil case.
Rivera and his 2 co-plaintiffs received a favorable decision. Atty. Angeles received almost PhP
50,000 from one of the defendants in the case as partial fulfillment of the judgement against the
latter. Atty. Angeles, however, never told his clients of the amount he had received and never
remitted the same to him, leaving them to discover such fact on their own. Rivera and his coplaintiffs filed an administrative complaint for disbarment against Atty. Angeles.
Held: GUILTY. Atty. Angeles was not disbarred but the Court ruled that his act amounted to
serious misconduct. The Court has repeatedly stressed the importance of integrity and good
moral character as part of a lawyers equipment in the practice of his profession. For it cannot
be denied that the respect of litigants for the profession is inexorably diminished whenever a
member of the Bar betrays their trust and confidence. The Court is not oblivious of the right of a
lawyer to be paid for the legal services he has extended to his client but such right should not be
exercised whimsically by appropriating to himself the money intended for his clients. There
should never be an instance where the victor in litigation loses everything he won to the fees of
his own lawyer. For deceit in dealing with his client, Atty. Angeles was suspended from the
practice of law for 1 year.
Aquilino Q. Pimentel, Jr. vs. Attys. Antonio M. Llorente and Ligaya P. Salayon
A.C. No. 4690. August 29, 2000
Facts: Attys. Antonio Llorente and Ligaya Salayon were election officers of the COMELEC and
held the position of Chairman and Vice-Chairman respectively for the Pasig City Board of
Candidates. The respondents helped conduct and oversee the 1995 elections. Then Senatorial
candidate Aquilino Pimentel, Jr. alleged that the respondents tampered with the votes received
by them by either adding more votes for particular candidates in their Statement of Votes (SoV)
or reducing the number of votes of particular candidates in their SoV. Pimentel filed an
administrative complaint for their disbarment. Respondents argued that the discrepancies were
due to honest mistake, oversight and fatigue. Respondents also argued that the IBP Board of
Governors had already exonerated them from any offense and that the motion for
reconsideration filed by Pimentel was not filed in time.
Held: GUILTY. Respondents do not dispute the fact that massive irregularities attended the
canvassing of the Pasig City election returns. The only explanation they could offer for such
irregularities is that the same could be due to honest mistake, human error, and/or fatigue
on the part of the members of the canvassing committees who prepared the SoVs. There is
a limit, we believe, to what can be construed as an honest mistake or oversight due to
fatigue, in the performance of official duty. The sheer magnitude of the error renders the