Teodoro R. Rivera vs. Atty. Sergio AngelesA.C. No. 2519August 29, 2000

FACTS:Complainants filed a Complaint for Disbarment against Atty. Sergio

Angeles on the grounds of Deceit and Malpractice. 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 PHP 42,999 from one of the defendants in the case as partial fulfillment of the judgment 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 co-plaintiffs filed an administrative complaint for disbarment against Atty. Angeles.

ISSUE:Whether or not Atty. Angeles is guilty of deceit and malpractice

RULING:Yes. 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 lawyer’s equipment in the practice of his profession. Respondents act of deceit and malpractice indubitably demonstrated his failure to live up to his sworn duties as a lawyer. The Supreme Court 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. 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. For deceit in dealing with his client, Atty. Angeles was suspended from the practice of law for 1 year.