CASE DIGEST: Anglo v.

Valencia
AC No. 10567 25 February 2015
Ponente: Perlas-Bernabe, J.

Doctrine: Representing conflicting interests is unethical for a lawyer.

FACTS:
1. Complainant Anglo engaged the services of Valencia Ciocon Dabao Valencia Dela Paz
Dionela Pandan Rubica Law Office (law firm) in the labor case in which Anglo was the
respondent. Atty. Dionela, a partner of the firm, represented the complainant. The labor
case was terminated on June 5, 2008 upon the agreement of both parties.
2. On September 18, 2009, a criminal case for qualified theft was filed against Anglo and his
wife by the Farms Agricultural Corporation (FEVE Farms) acting through a certain Michael
Villacorta. Villacorta was represented by the law firm, the same law office which
represented the complainant in the labor case.
3. Anglo filed a disbarment case against the partners of the law firm for representing
conflicting interests.
4. The respondents contended that the conflict-of-interest principle was not violated. It has
been the practice of their firm to allow their lawyers to receive their own professional
fees exclusively, except for contributions to the firm to defray office maintenance
expenses. This “arrangement” gives no room for lawyers to discuss their clientele to other
lawyers and associates. Specifically, Atty. Dionela contended he could have not breached
the conflict-of-interest principle because complainant did not confide any secret during
the time the labor case was pending that would have been used in the criminal case with
FEVE Farms.

ISSUE: Whether or not the partners of the law firm are guilty of representing conflicting interests
when they agreed to represent FEVE Farms

RULING: YES, the partners of the law firm are guilty of representing conflicting interests and
violated Canons 15 and 21 and Rule 15.03

Canon 15: A lawyer shall observe candor, fairness, and loyalty in all his dealings and
transactions with his clients.

Rule 15.03 – A lawyer shall not represent conflicting interests except by written consent
of all concerned given after a full disclosure of facts.

Canon 21: A lawyer shall preserve the confidences and secrets of his client even after the
attorney-client relationship is terminated.

1
There are two tests used to determine whether or not conflict of interest exists:

1. Whether or not in behalf of one client, it is the lawyer’s duty to fight for an issue or
claim but it is his duty to oppose it for the other client.
2. Whether the acceptance of a new relation will prevent an attorney from the full
discharge of his undivided fidelity and loyalty or invite suspicion of unfaithfulness or
double dealing in the performance thereof.

In this case, respondents represented complainant in the labor case. However, after the
termination of the case, the respondents agreed to represent FEVE Farms, a new client, in filing
a criminal case against the complainant, its former client. According to the Supreme Court the
acceptance of the criminal case by the respondents is unethical and constitutes conflict of
interest. The Supreme Court (SC) observed that the unethical acceptance arose from the law
firm’s failure to implement a case tracking system for all its handling lawyers. This lack of case
organization, as a result, renders client’s secrets vulnerable to adverse pressure and erodes the
unimpaired trust and confidence reposed by the client in him. As has been ruled by the SC in
previous cases, the termination of attorney-client relationship provides no justification for a
lawyer to represent an interest adverse to his former client.

Hence, the respondents are guilty of representing conflicting interests and are meted the penalty
of REPRIMAND, with a stern warning that a repetition of the same or similar infraction would be
dealt with more severely.