COMMINGLING OF CLIENT’S FUND

 Lawyer shall keep the funds of each client separate and apart from his own and those of others
kept by him.
 Failure to return gives rise to the presumption that the lawyer has appropriated the fund for his
own use (Sison v. Valdez, July 31 2017)
 This obligations flows from the highly fiduciary character of attorney-client relationship.
 An attorney should keep a record and report promptly the money of the client that has come to
his possession and
 At all times reputation for honesty and fidelity to private trust should be maintained.
 Failure to do so is violation of Canon 16 of CPR and failure to return funds may constitute a
prima facie evidence of swindling or estafa (Belleza v. Atty Macasa, July 23, 2009).
 Any violation to the said obligation may result to disbarment depending on circumstances of the
case. (Licuanan v. Atty. Melo, February 9 1989)