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A.C. No. 2285 August 12, 1991 Tiania signed.

Tiania signed. Then Ocampo made Tiania sign a Compromise With the money paid by Blaylock, the Angel spouses bought another
Agreement 3 which the latter signed without reading. parcel of land. Again, Ocampo prepared the Deed of Sale which was
MARIA TIANIA complainant, vs. ATTY. AMADO signed by the vendor, a certain Laura Dalanan, and the Angel spouses, as
OCAMPO, respondent. Two years from the submission of the Compromise Agreement, Tiania the vendees. In addition, Ocampo allegedly made the Angel spouses sign
was shocked when she received an order to vacate 4 the property in two (2) more documents which, accordingly, were made parts of the sale
A.C. No. 2302 August 12, 1991 question. To hold off her ejectment for another two years, Ocampo transaction.
advised Tiania to pay him a certain amount for the sheriff. 5
FELICIDAD LLANOS ANGEL and ALFONSO Those two (2) documents later turned out to be a Real Estate Mortgage of
ANGEL, complainants, vs. ATTY. AMADO OCAMPO, respondent. Ocampo denied the charges in detail. Although he handled some legal the same property purchased from Laura Dalanan and a Promissory
problems and executed some notarial deeds for Tiania from 1966-1971, Note, 9 both in favor of Blaylock.
PER CURIAM:p Tiania had also engaged the services of various counsel to represent her
in several criminal and civil cases, involving violations of municipal The Angel spouses never realized the nature of the said documents until
These disbarment proceedings against Attorney Amado Ocampo were ordinances and estafa. Thus, he could not be the complainant's "retaining they received a complaint naming them as defendants in a collection
filed by Maria Tiania, docketed as Administrative Case No. 2285, and by counsel" in all her legal problems and court cases. suit 10 filed by Ocampo on behalf of the plaintiff, Commercial Corporation
Spouses Felicidad Angel and Alfonso Angel (hereinafter referred to as the of Olongapo, a firm headed by Blaylock.
Angel Spouses), docketed as Administrative Case No. 2302. Ocampo then insisted that he appeared on behalf of Mrs. Blaylock, and
not as counsel of Tiania, in Civil Case No. 1104-0. He never saw or talked The Angel spouses added that Ocampo reassured them that there was no
Both cases were consolidated upon the instance of Atty. Amado Ocampo to Tiania from the time the said civil case was filed up to the pre-trial and need for them to engage the services of a new lawyer since he will take
who, in his answer, denied the imputations. as such could not have discussed with her the complaint, the hiring of care of everything. Ocampo even appeared as counsel for the Angel
another lawyer, and more so the preparation of the answer in the said spouses in a civil case 11 they filed sometime in 1976. However, in 1978, a
The complaints in Adm. Case No. 2285 and Adm. Case No. 2302 were case. He admitted that during the pre-trial of the said case, Tiania showed Notice to Vacate, 12 on the basis of the two (2) documents they signed in
filed on July 14, 1981 and August 10, 1981, respectively. to him a document which supported her claim, over the property in 1972, was served on them.
question. Ocampo, after going over the document, expressed his doubts
On January 27, 1982, after Atty. Ocampo filed his comment, the Court about it authenticity. This convinced Tiania to sign a Compromise These acts, the complainants charge, violate the ethics of the legal
referred the case to the Solicitor General for investigation, report, and Agreement and to pay the acquisition cost to Blaylock over a period of six profession. They lost their property as a result of the respondent's
recommendation as provided, then, by Section 27, Rule 138 of the Rules (6) months. 6 fraudulent manipulation, taking advantage of his expertise in law against
of Court. 1 his own unsuspecting and trusting clients.
But Tiania never fulfilled any of her obligations. She moreover made the
It was only on April 25, 1990, more than eight years later, that the Office of situation worse by selling the contested property to a third party even after As in the first case, Ocampo presented an elaborate explanation.
the Solicitor General returned the entire records of Adm. Cases Nos. 2285 an alias writ of execution had ordered the transfer of the possession of the
and 2302 with the accompanying complaint for disbarment. disputed property to Blaylock. 7 Ocampo alleged that it was his client, Mrs. Concepcion Blaylock, who
introduced to him the Angel spouses in 1972. Blaylock wanted Ocampo to
Hence, the administrative complaint for disbarment in both cases was Significantly, the petition was filed five years after Tiania allegedly suffered check the background of the Angel spouses in connection with the loan
filed. "terrible shock" upon receiving the Notice to Vacate. they were seeking from Blaylock.

ADMINISTRATIVE CASE NO. 2285 Citing Arboleda v. Gatchalian, 8 Ocampo said that the overdue filing of a In his interview with Mrs. Angel, Ocampo learned that the amount of
complaint against a lawyer should already create a suspicion about the twenty thousand pesos (P20,000.00) to be loaned to the Angel spouses
Maria Tiania claims in her verified complaint that respondent Amado motives of the complainant or the merit of the complaint. from Blaylock would be used to repurchase the property at 39 Fendler
Ocampo who has been her "retaining (sic) counsel" in all her legal Street, Olongapo City, which the Angel spouses had originally owned. In
problems and court cases as early as 1966, has always had her ADMINISTRATIVE CASE NO. 2302 turn, the Angel spouses should sell the same to Blaylock.
unqualified faith and confidence.
The Angel spouses, complainants in A.C. No. 2302, allege that sometime Ocampo himself facilitated the transfer by delivering to the complainants
In 1972, one Mrs. Concepcion Blaylock sued Tiania for ejectment 2 from a in 1972, they sold their house in favor of Blaylock (the same Mrs. the P20,000.00 for the repurchase of the Fendler property. This in turn
parcel of land described as "Lot 4131, TS-308." Ocampo appeared for Concepcion Blaylock in A.C. No. 2285) for the amount of seventy was sold to
Tiania and also for Blaylock. Tiania confronted Ocampo about this but the thousand pesos, (P70,000.00). Ocampo (the same respondent Atty. Blaylock. 13
latter reassured Tiania that he will take care of everything and that there Amado Ocampo), acted as their counsel and prepared the Deed of Sale of
was no need for Tiania to hire a new lawyer since he is still Tiania's a Residential House and Waiver of Rights Over a Lot. Since the sale of the Fendler property would render the Angel spouses
lawyer. Ocampo prepared the answer in the said ejectment case, which homeless, they suggested to Blaylock that they would need an additional
loan of forty thousand pesos (P40,000.00) to purchase from Laura
Legal Ethics (Full Text Cases) Canons 13-14 I VIADA (2013-2014), Compiled by: Garcia
Dalanan another property located at #66 Kessing Street, Olongapo City, At the pre-trial of Civil Case No. 11 04-0, the respondent appeared as present administrative cases, we find no cogent reason to disturb the
which was mortgaged in favor of a certain Salud Jimenez. counsel for the plaintiff and while appearing for the same, gave advice and findings of the Solicitor General upholding the complaints against the
warnings to the defendant which paved the way for an amicable respondent. Indeed, the aforementioned acts of the respondent in
To expedite the transfer of the Kessing property from Dalanan to the settlement and which may have prejudiced the defendant's rights. representing Blaylock, and at the same time advising Tiania, the opposing
Angel spouses, Ocampo himself delivered to Salud Jimenez twenty two party, as in the first administrative case, and once again representing
thousand (P22,000.00) pesos from Blaylock in payment of the mortgage b) Administrative Case No. 2302 Blaylock and her interest while handling the legal documents of another
debt of Dalanan. The balance of eighteen thousand (P18,000.00) pesos opposing party as in the second case, whether the said actions were
was then delivered to Mrs. Angel upon the execution of the final (1) Respondent while acting as counsel for Mrs. Concepcion Blaylock and related or totally unrelated, constitute serious misconduct. They are
documents between the Angel spouses and Dalanan. 14 her Commercial Credit Corporation; also acted as counsel of the improper to the respondent's office as attorney.
complainant Mrs. Angel when he prepared the Deed of Sale of a
Ocampo explained that simultaneously he executed a Real Estate Residential House and Waiver of Rights Over a Lot for Mrs. Angel in favor However, taking into consideration the advanced age of the respondent,
Mortgage over the Kessing property and a Promissory Note for the Angel of Zenaida Blaylock, daughter of Concepcion Blaylock. who would have reached seventy three (73) years, as of this date, the
spouses in favor of Blaylock for the amount of seventy-four thousand Court, while uncompromisingly firm in its stand against erring lawyers,
seventy five (P74,075.00) pesos. Although only forty thousand (2) Respondent, while acting as counsel for Mrs. Concepcion Blaylock and nonetheless appreciates the advance years of the respondent in his favor.
(P40,000.00) was received by Mrs. Angel and Dalanan, the difference her Commercial Credit Corporation, also acted as counsel of Mrs. Angel
between seventy-four thousand seventy five pesos and forty thousand when he proceeded to Cavite and paid Salud Jimenez the sum of twenty WHEREFORE, finding the respondent Atty. Amado Ocampo guilty of
pesos represented the interests in advance over a period of five years in two thousand pesos (P22,000.00) for Dalanan's Kessing Property. malpractice and gross misconduct in violation of the Code of Professional
which the loan would be paid. Responsibility, we hereby SUSPEND him from the practice of law for a
(3) Respondent was representing conflicting interests when he period of one (1) year.
When the monthly amortizations became due, the Angel spouses never simultaneously prepared the Deed of Sale of the Kessing property in favor
paid any of it despite repeated demands from Blaylock. Blaylock assigned of Mrs. Angel and the Real Estate Mortgage for the same property to be Let this Decision be spread upon the personal records of the respondent
the promissory note to the Commercial Credit Corporation which later on signed by Mrs. Angel in favor of Mrs. Blaylock and her Commercial Credit and copies thereof furnished to all courts and to the Integrated Bar of the
filed a civil case against the Angel spouses. Corporation. Philippines.

The Angel spouses never filed an answer and were declared in default. (4) Respondent used Mrs. Angel by pretending to protect her interest as
Upon execution, the Kessing property was levied on and sold at public his client in Civil Case No. 2020-0, when admittedly he was only "forced to
auction followed by a Notice to Vacate. help and assist Mrs. Angel in said case to protect the property of Mrs.
Blaylock."
Ocampo admits appearing for the Angel spouses in Civil Case No. 1458,
filed July 26, 1976, but only because he had his client Blaylock's interest Was the respondent guilty of representing conflicting interests?
foremost in his mind.
The specific law applicable in both administrative cases is Rule 15.03 of
Blaylock, through Ocampo, had sued one Benedicto Hermogeno a lessee the Code of Professional Responsibility which provides:
of Blaylock's property, in an ejectment case. But before the institution of
the ejectment case, Hermogeno leased out the same premises to Mrs. A lawyer shall not represent conflicting interest except by written consent
Angel on June 14, 1976. Four days later, Hermogeno without the of all concerned given after a full disclosure of the facts.
knowledge and consent of Mrs. Angel, regained possession of the leased
premises. Thus, Ocampo, in filing a complaint against Hermogeno on We prohibit the representation of conflicting interests not only because the
behalf of Blaylock, was also doing so for Mrs. Angel. relation of attorney and client is one of trust and confidence of the highest
degree, but also because of the principles of public policy and good taste.
These explanations notwithstanding, the Solicitor General charged the An attorney has the duty to deserve the fullest confidence of his client and
respondent Atty. Amado Ocampo with malpractice and gross misconduct represent him with undivided loyalty. Once this confidence is abused, the
punishable under Section 27 of Rule 138 of the Rules of Court of the entire profession suffers. 15
Philippines and violation of his oath of office as an attorney for the
following acts: The test of the conflict of interest in disciplinary cases against a lawyer is
whether or not the acceptance of a new relation will prevent an attorney
a) Administrative Case No. 2285 from the full discharge of his duty of undivided fidelity and loyalty to his
client or invite suspicion of unfaithfulness or double-dealing in the
performance thereof. 16 Considering this criterion and applying it to the
Legal Ethics (Full Text Cases) Canons 13-14 I VIADA (2013-2014), Compiled by: Garcia
Adm. Case No. 6708 August 25, 2005 Risk Management Specialists, Inc., (QRMSI), which was later registered first, the respondent was still complainants counsel of record in the
under complainants name, with the respondent as a "silent partner" ejectment case when he filed, as legal counsel of AIB, the replevin case
(CBD Case No. 01-874) represented by his associate Atty. Gerardo P. Hernandez. The respondent against her; and second, the respondent was still the legal counsel of AIB
was paid attorneys fees for his legal services in organizing and when he advised the complainant on the incorporation of another security
FELICITAS S. QUIAMBAO, Complainant, vs. ATTY. NESTOR A. incorporating QRMSI. He also planned to "steal" or "pirate" some of the agency, QRMSI, and recommended his former law partner, Atty. Gerardo
BAMBA, Respondent. more important clients of AIB. While serving as legal counsel for AIB and a Hernandez, to be its corporate secretary and legal counsel and also when
"silent partner" of QRMSI, he convinced complainants brother Leodegario he conferred with Leodegario to organize another security agency, SESSI,
RESOLUTION Quiambao to organize another security agency, San Esteban Security where the respondent became an incorporator, stockholder, and
Services, Inc. (SESSI) where he (the respondent) served as its president. Thus, the investigating commissioner recommended that the
DAVIDE, JR., C.J.: incorporator, director, and president. The respondent and Leodegario then respondent be suspended from the practice of law for one year.
illegally diverted the funds of AIB to fund the incorporation of SESSI, and
We are aware of the hapless fact that there are not enough lawyers to likewise planned to eventually close down the operations of AIB and The IBP Board of Governors adopted and approved the investigating
serve an exploding population. This unfortunate state of affairs, however, transfer the business to SESSI.3 commissioners report and recommendation, but reduced the penalty from
will not seize this Court from exercising its disciplinary power over lawyers one year to a stern reprimand.7
culpable of serious indiscretions. The incidence of public force must be For his part, the respondent admits that he represented the complainant in
deployed to bear upon the community to eventually forge a legal the aforementioned ejectment case and later represented AIB in the The issue in this case is whether the respondent is guilty of misconduct for
profession that provides quality, ethical, accessible, and cost-effective replevin case against her. He, however, denies that he was the "personal representing conflicting interests in contravention of the basic tenets of the
legal service to our people and whose members are willing and able to lawyer" of the complainant, and avers that he was made to believe that it legal profession.
answer the call to public service. was part of his function as counsel for AIB to handle even the "personal
cases" of its officers. Even assuming that the complainant confided to him Rule 15.03, Canon 5 of the Code of Professional Responsibility provides:
In this administrative case for disbarment, complainant Felicitas S. privileged information about her legal interests, the ejectment case and "A lawyer shall not represent conflicting interests except by written
Quiambao charges respondent Atty. Nestor A. Bamba with violation of the the replevin case are unrelated cases involving different issues and consent of all concerned given after a full disclosure of the facts." This
Code of Professional Responsibility for representing conflicting interests parties and, therefore, the privileged information which might have been prohibition is founded on principles of public policy and good taste. 8 In the
when the latter filed a case against her while he was at that time gathered from one case would have no use in the other. At any rate, it was course of a lawyer-client relationship, the lawyer learns all the facts
representing her in another case, and for committing other acts of the complainant herself who insisted that he stay as her counsel despite connected with the clients case, including the weak and strong points of
disloyalty and double-dealing. the perceived differences among her, her brother, and AIB over the motor the case. The nature of that relationship is, therefore, one of trust and
vehicle subject of the replevin case. The complainant even asked him to confidence of the highest degree.9 It behooves lawyers not only to keep
From June 2000 to January 2001, the complainant was the president and assist her in her monetary claims against AIB.4 inviolate the clients confidence, but also to avoid the appearance of
managing director of Allied Investigation Bureau, Inc. (AIB), a family- treachery and double-dealing for only then can litigants be encouraged to
owned corporation engaged in providing security and investigation The respondent also denies the charge raised by the complainant in her entrust their secrets to their lawyers, which is of paramount importance in
services. She avers that she procured the legal services of the respondent position paper that he agreed to be a "silent partner" of QRMSI through the administration of justice.10
not only for the corporate affairs of AIB but also for her personal case. his nominee, Atty. Gerardo P. Hernandez, who was his former law partner.
Particularly, the respondent acted as her counsel of record in an ejectment He declined complainants offer to assume that role and suggested Atty. In broad terms, lawyers are deemed to represent conflicting interests
case against Spouses Santiago and Florita Torroba filed by her on 29 Hernandez in his place; thus, 375 shares of stock were registered in Atty. when, in behalf of one client, it is their duty to contend for that which duty
December 2000 before the Metropolitan Trial Court (MeTC) of Paraaque Hernandezs name as consideration of his (Atty. Hernandezs) legal to another client requires them to oppose.11 Developments in
City, which was docketed as Civil Case No. 11928. She paid attorneys services as corporate secretary and legal counsel of QRMSI. The jurisprudence have particularized various tests to determine whether a
fees for respondents legal services in that case. 1 About six months after respondent also denies that he convinced complainants brother lawyers conduct lies within this proscription. One test is whether a lawyer
she resigned as AIB president, or on 14 June 2001, the respondent filed Leodegario to organize another security agency and that the funds of AIB is duty-bound to fight for an issue or claim in behalf of one client and, at
on behalf of AIB a complaint for replevin and damages against her before were unlawfully diverted to SESSI. It was to complement the business of the same time, to oppose that claim for the other client. 12 Thus, if a
the MeTC of Quezon City for the purpose of recovering from her the car of AIB, which was then in danger of collapse, that SESSI was established. lawyers argument for one client has to be opposed by that same lawyer in
AIB assigned to her as a service vehicle. This he did without withdrawing Leodegarios wife and her son have the effective control over SESSI. arguing for the other client, there is a violation of the rule.
as counsel of record in the ejectment case, which was then still pending.2 Respondents subscribed shareholdings in SESSI comprise only 800
shares out of 12,500 subscribed shares. He serves AIB and SESSI in Another test of inconsistency of interests is whether the acceptance of a
Apart from the foregoing litigation matter, the complainant, in her Position different capacities: as legal counsel of the former and as president of the new relation would prevent the full discharge of the lawyers duty of
Paper, charges the respondent with acts of disloyalty and double-dealing. latter.5 undivided fidelity and loyalty to the client or invite suspicion of
She avers that the respondent proposed to her that she organize her own unfaithfulness or double-dealing in the performance of that duty.13 Still
security agency and that he would assist her in its organization, causing In his Report and Recommendation6 dated 31 August 2004, the another test is whether the lawyer would be called upon in the new
her to resign as president of AIB. The respondent indeed assisted her in investigating commissioner of the IBP found the respondent guilty of relation to use against a former client any confidential information acquired
December 2000 in the formation of another security agency, Quiambao representing conflicting interests based on the following undisputed facts: through their connection or previous employment.14
Legal Ethics (Full Text Cases) Canons 13-14 I VIADA (2013-2014), Compiled by: Garcia
The proscription against representation of conflicting interests applies to a become an incorporator, stockholder, and president of SESSI, which is outstanding shares; while his four other siblings who are permanent
situation where the opposing parties are present clients in the same action also a security agency. He justified his act by claiming that that while both residents in the United States own the remaining 40%. 24 This prohibition
or in an unrelated action. It is of no moment that the lawyer would not be AIB and SESSI are engaged in security agency business, he is serving in notwithstanding, the respondent organized SESSI, with Leodegarios wife
called upon to contend for one client that which the lawyer has to oppose different capacities. As the in-house legal counsel of AIB, he "serves its and son as majority stockholders holding about 70% of the outstanding
for the other client, or that there would be no occasion to use the legal interest the parameter of which evolves around legal matters" such shares and with him (the respondent), as well as the rest of the
confidential information acquired from one to the disadvantage of the other as protecting the legal rights and interest of the corporation; conducting an stockholders, holding minimal shares.25 In doing so, the respondent
as the two actions are wholly unrelated. It is enough that the opposing investigation or a hearing on violations of company rules and regulations virtually allowed Leodegario and the latters wife to violate or circumvent
parties in one case, one of whom would lose the suit, are present clients of their office employees and security guards; sending demand letters in the law by having an interest in more than one security agency. It must be
and the nature or conditions of the lawyers respective retainers with each collection cases; and representing the corporation in any litigation for or noted that in the affidavit26 of Leodegarios wife, she mentioned of their
of them would affect the performance of the duty of undivided fidelity to against it. And as president of SESSI, he serves the operational aspects conjugal property. In the absence of evidence to the contrary, the property
both clients.15 of the business such as "how does it operate[], how much do they price relation of Leodegario and his wife can be presumed to be that of conjugal
their services, what kind or how do they train[] their security guards, how partnership of gains; hence, the majority shares in AIB and SESSI are the
In this case, it is undisputed that at the time the respondent filed the they solicit clients." Thus, conflict of interest is far-fetched. Moreover, the conjugal property of Leodegario and his wife, thereby placing themselves
replevin case on behalf of AIB he was still the counsel of record of the respondent argues that the complainant, not being a stockholder of AIB in possession of an interest in more than one security agency in
complainant in the pending ejectment case. We do not sustain and SESSI, has no right to question his alleged conflict of interest in contravention of R.A. No. 5487. Thus, in organizing SESSI, the
respondents theory that since the ejectment case and the replevin case serving the two security agencies.22 respondent violated Rule 1.02, Canon 1 of the Code of Professional
are unrelated cases fraught with different issues, parties, and subject Responsibility, which mandates lawyers to promote respect for the law
matters, the prohibition is inapplicable. His representation of opposing While the complainant lacks personality to question the alleged conflict of and refrain from counseling or abetting activities aimed at defiance of the
clients in both cases, though unrelated, obviously constitutes conflict of interests on the part of the respondent in serving both security agencies, law.
interest or, at the least, invites suspicion of double-dealing. While the we cannot just turn a blind eye to respondents act. It must be noted that
respondent may assert that the complainant expressly consented to his the proscription against representation of conflicting interests finds As to the recommendation that the penalty be reduced from a suspension
continued representation in the ejectment case, the respondent failed to application where the conflicting interests arise with respect to the same of one year to a stern warning, we find the same to be without basis. We
show that he fully disclosed the facts to both his clients and he failed to general matter however slight the adverse interest may be. It applies even are disturbed by the reduction made by the IBP Board of Governors of the
present any written consent of the complainant and AIB as required under if the conflict pertains to the lawyers private activity or in the performance penalty recommended by the investigating commissioner without clearly
Rule 15.03, Canon 15 of the Code of Professional Responsibility. of a function in a non-professional capacity.23 In the process of determining and distinctly stating the facts and reasons on which that reduction is
whether there is a conflict of interest, an important criterion is probability, based.
Neither can we accept respondents plea that he was duty-bound to not certainty, of conflict.
handle all the cases referred to him by AIB, including the personal cases Section 12(a), Rule 139-B of the Rules of Court reads in part as follows:
of its officers which had no connection to its corporate affairs. That the Since the respondent has financial or pecuniary interest in SESSI, which
representation of conflicting interest is in good faith and with honest is engaged in a business competing with his clients, and, more SEC. 12. Review and decision by the Board of Governors.
intention on the part of the lawyer does not make the prohibition importantly, he occupies the highest position in SESSI, one cannot help
inoperative.16 Moreover, lawyers are not obliged to act either as an adviser entertaining a doubt on his loyalty to his client AIB. This kind of situation (a) Every case heard by an investigator shall be reviewed by the IBP
or advocate for every person who may wish to become their client. They passes the second test of conflict of interest, which is whether the Board of Governors upon the record and evidence transmitted to it by the
have the right to decline such employment, subject, however, to Canon 14 acceptance of a new relationship would prevent the full discharge of the Investigator with his report. The decision of the Board upon such review
of the Code of Professional Responsibility.17 Although there are instances lawyers duty of undivided fidelity and loyalty to the client or invite shall be in writing and shall clearly and distinctly state the facts and the
where lawyers cannot decline representation,18 they cannot be made to suspicion of unfaithfulness or double-dealing in the performance of that reasons on which it is based.
labor under conflict of interest between a present client and a prospective duty. The close relationship of the majority stockholders of both
one.19 companies does not negate the conflict of interest. Neither does his We may consider the resolution of the IBP Board of Governors as a
protestation that his shareholding in SESSI is "a mere pebble among the memorandum decision adopting by reference the report of the
Additionally, in his position paper, the respondent alleges that when the sands." investigating commissioner. However, we look with disfavor the change in
complainant invited the respondent to join QRMSI, he "vehemently the recommended penalty without any explanation therefor. Again, we
refused to join them due to his perception of conflicting interest as he In view of all of the foregoing, we find the respondent guilty of serious remind the IBP Board of Governors of the importance of the requirement
was then (and still is at present) the Legal Counsel" of AIB, which is also a misconduct for representing conflicting interests. to announce in plain terms its legal reasoning, since the requirement that
security agency.20 To bolster his allegation, he invoked the affidavits of its decision in disciplinary proceedings must state the facts and the
complainants witnesses which contained statements of his apprehension Furthermore, it must be noted that Republic Act No. 5487, otherwise reasons on which its decision is based is akin to what is required of the
of conflict of interest should he join QRMSI.21 known as the Private Security Agency Law, prohibits a person from decisions of courts of record.27 The reasons for handing down a penalty
organizing or having an interest in more than one security agency. From occupy no lesser station than any other portion of the ratio.
Surprisingly, despite his apprehension or awareness of a possible conflict respondents position paper, it can be culled that Leodegario Quiambao is
of interest should he join QRMSI, the respondent later allowed himself to the president and managing director of AIB, holding 60% of the
Legal Ethics (Full Text Cases) Canons 13-14 I VIADA (2013-2014), Compiled by: Garcia
In similar cases where the respondent was found guilty of representing
conflicting interests a penalty ranging from one to three years suspension
was imposed.28 In this case, we find that a suspension from the practice of
law for one year is warranted.

WHEREFORE, respondent Atty. Nestor A. Bamba is hereby


held GUILTY of violation of Rule 15.03 of Canon 15 and Rule 1.02 of
Canon 1 of the Code of Professional Responsibility. He
is SUSPENDED from the practice of law for a period of ONE (1)
YEAR effective from receipt of this Resolution, with a warning that a
similar infraction in the future shall be dealt with more severely.

Let copies of this Resolution be furnished to the Office of the Bar


Confidant and the Integrated Bar of the Philippines.

SO ORDERED.

Legal Ethics (Full Text Cases) Canons 13-14 I VIADA (2013-2014), Compiled by: Garcia