G.R. No. A.C. No. 10910. January 12, 2016.
ANTERO M. SISON, JR., Complainant, vs. ATTY. MANUEL N. CAMACHO, Respondent.

FACTS

Complainant Atty. Antero M. Sison, Jr., president of Marsman-Drysdale Agribusiness Holdings Inc. (MDAHI), charged respondent Atty. Manuel Camacho with violating the Code of Professional Responsibility. Atty. Camacho was MDAHI’s counsel in an insurance claim case. He proposed increasing the claim, which required additional docket fees of P1,288,260.00. MDAHI gave this amount to its corporate secretary, who handed it to Atty. Camacho on May 27, 2011. Atty. Camacho promised to issue a receipt but never did. Unbeknownst to MDAHI, the trial court had already rendered a decision in its favor for approximately P65,000,000.00 on May 26, 2011. Subsequently, Atty. Camacho recommended a compromise settlement for P15,000,000.00. MDAHI refused and did not sign the conforme on his letter. Despite this, Atty. Camacho filed a Satisfaction of Judgment stating the parties had entered into a compromise. When confronted, Atty. Camacho claimed he gave the docket fee money to the clerk of court as the payment period had lapsed. In his defense, Atty. Camacho claimed he had authority to compromise and that the P1,288,260.00 formed part of his attorney’s fees, citing a favorable trial court order. The Integrated Bar of the Philippines Commission on Bar Discipline found violations and initially recommended a one-year suspension, later modified to six months.

ISSUE

Whether Atty. Manuel N. Camacho violated Rules 1.01 and 16.01 of the Code of Professional Responsibility.

RULING

Yes, Atty. Camacho violated both rules. The Court found that he entered into a compromise agreement without the written special authority from his client, as required by Article 1878 of the Civil Code and Section 23, Rule 138 of the Rules of Court. His act of filing a Satisfaction of Judgment without MDAHI’s written conformity constituted dishonest and deceitful conduct in violation of Rule 1.01. Furthermore, he violated Rule 16.01 by failing to properly account for the P1,288,260.00 received from his client, which was intended for docket fees. His claim that it constituted attorney’s fees was belied by the circumstances and his own prior representations. The Court held that the pendency of a related criminal case for estafa did not preclude the resolution of the administrative charge, as the issues and quantum of proof differ. Considering the gravity of his violations, which demonstrated a betrayal of client trust and a lack of the honesty and integrity required of lawyers, the penalty of disbarment was imposed. Atty. Manuel N. Camacho is DISBARRED from the practice of law, and his name is ordered stricken from the Roll of Attorneys. He is also ORDERED to return the amount of P1,288,260.00 to MDAHI within ninety (90) days from the finality of the decision.