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Constitutional Law I

Key words: overtime and separation pay,


Philippine Racing Club Restaurant, Atty. Angeles

Manalang v. Angeles
A.C. No. 1558, March 10, 2003
Ponente: J. Quisumbing
I. Terms
Canon 17 A LAWYER OWES FIDELITY TO THE
CAUSE OF HIS CLIENT AND HE SHALL BE
MINDFUL OF THE TRUST AND CONFIDENCE
REPOSED IN HIM.
Rule 16.03 - A lawyer shall deliver the funds and
property of his client when due or upon demand.
However, he shall have a lien over the funds and
may apply so much thereof as may be necessary to
satisfy his lawful fees and disbursements, giving
notice promptly thereafter to his client. He shall
also have a lien to the same extent on all
judgments and executions he has secured for his
client as provided for in the Rules of Court.
II. Reliefs Sought
Administrative complaint for grave misconduct as a lawyer
III. Facts
Manalang and Cirilo (petitioners) filed a case
against their employer, Philippine Racing Club
Restaurant, for their overtime and separation pay
before the NLRC and Francisco Angeles
(respondent) was their counsel.
They obtained a favorable judgment and their
employer was asked to pay Php 6,500. However,
Atty. Angeles compromised and was only able to

collect Php 5,500 and it was allegedly obtained


without the consulting his clients.
OSG conducted several hearings but respondent
only appeared 3 times. It was then transferred to
the Committee on Bar Discipline of the IBP. Neither
party appeared despite prior due notice. The
Committee issued a resolution recommending that
respondent be suspended from the practice of law
for 2 years.

IV. Issue/s and Held


W/N Atty. Francisco F. Angeles should be
suspended from the practice of law because of
grave misconduct related to his clients funds.
o YES. A lawyer must possess standards for
honesty, integrity and fair dealing. Also, the
respondent exhibited an uncaring lack of
devotion to the interest of his clients as well
as want of zeal in the maintenance and
defense of their rights (violating Canon 17).
Moreover, he consistently failed to appear at
the hearings and more importantly, failed to
deliver upon the demand of Php 4,550
(minus fees) intended for his clients. This
demonstrated lack of integrity and propriety.
o The Court thereby suspends Atty. Angeles
from practice of law for a period of 6 months
and orders the respondent to pay the sum of
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Constitutional Law I

Php 2,275.00 each to complainants Honorio


Manalang and Florencio Cirillo, with interest
of 6% per annum from the time of filing this
complaint until fully paid.
V. Doctrine
A lawyer must possess standards for honesty,
integrity and fair dealing. Atty. Angeles conduct of
lack of devotion to the interest of his clients and as
well as zeal in the maintenance and defense of
their rights are clear signs of breach of his duty as
an officer of the Court.

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