4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701 4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701

grounded in the fiduciary obligation of loyalty. Throughout the

course of a lawyer-client relationship, the lawyer learns all the
facts connected with the client’s case, including the weak and
strong points of the case. Knowledge and information gathered in
the course of the relationship must be treated as sacred and
guarded with care. It behooves lawyers not only to keep inviolate
the client’s confidence, but also to avoid the appearance of
A.C. No. 6664. July 16, 2013.* treachery and double-dealing, for only then can litigants be
encouraged to entrust their secrets to their lawyers, which is
FERDINAND A. SAMSON, complainant, vs. ATTY. paramount in the administration of justice. The nature of that
EDGARDO O. ERA, respondent. relationship is, therefore, one of trust and confidence of the
highest degree.
Attorneys; Legal Ethics; Code of Professional Responsibility;
Same; Same; Same; Same; Even after the severance of the
Conflict of Interests; A lawyer shall not represent conflicting
relation, a lawyer should not do anything that will injuriously
interests except by written consent of all concerned given after a
affect his former client in any matter in which the lawyer
full disclosure of the facts.―Rule 15.03, Canon 15 of the Code of
previously represented the client. Nor should the lawyer disclose or
Professional Responsibility provides that: “A lawyer shall not
use any of the client’s confidences acquired in the previous
represent conflicting interests except by written consent of all
relation.―Contrary to Atty. Era’s ill-conceived attempt to explain
concerned given after a full disclosure of the facts.” Atty. Era thus
his disloyalty to Samson and his group, the termination of the
owed to Samson and his group entire devotion to their genuine
attorney-client relationship does not justify a lawyer to represent
interest, and warm zeal in the maintenance and defense of their
an interest adverse to or in conflict with that of the former client.
rights. He was expected to exert his best efforts and ability to
The spirit behind this rule is that the client’s confidence once
preserve the clients’ cause, for the unwavering loyalty displayed
given should not be stripped by the mere expiration of the
to his clients likewise served the ends of justice.
professional employment. Even after the severance of the relation,
Same; Same; Same; Same; The rule prohibiting conflict of a lawyer should not do anything that will injuriously affect his
interest was fashioned to prevent situations wherein a lawyer former client in any matter in which the lawyer previously
would be representing a client whose interest is directly adverse to represented the client. Nor should the lawyer disclose or use any
any of his present or former clients.―The rule prohibiting conflict of the client’s confidences acquired in the previous relation. In
of interest was fashioned to prevent situations wherein a lawyer this regard, Canon 17 of the Code of Professional Responsibility
would be representing a client whose interest is directly adverse expressly declares that: “A lawyer owes fidelity to the cause of his
to any of his client and he shall be mindful of the trust and confidence reposed
in him.”
_______________ Same; Same; Same; Same; The protection given to the client is
* EN BANC. perpetual and does not cease with the termination of the litigation,
nor is it affected by the client’s ceasing to employ the attorney and
retaining another, or by any other change of relation between
242
them.―The lawyer’s highest and most unquestioned duty is to
protect the client at all hazards and costs even to himself. The
242 SUPREME COURT REPORTS ANNOTATED pro-

Samson vs. Era 243

present or former clients. In the same way, a lawyer may only be VOL. 701, JULY 16, 2013 243
allowed to represent a client involving the same or a substantially
related matter that is materially adverse to the former client only Samson vs. Era
if the former client consents to it after consultation. The rule is

www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 1/14 www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 2/14

4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701 4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701

tection given to the client is perpetual and does not cease with the counts of estafa in the Regional Trial Court, Branch 96
termination of the litigation, nor is it affected by the client’s (RTC), in Quezon City.2
ceasing to employ the attorney and retaining another, or by any In April 2003, Atty. Era called a meeting with Samson
other change of relation between them. It even survives the death and his relatives to discuss the possibility of an amicable
of the client. settlement with Sison and her cohorts. He told Samson and
the others that undergoing a trial of the cases would just be
ADMINISTRATIVE CASE in the Supreme Court. a waste of time, money and effort for them, and that they
Disbarment. could settle the cases with Sison and her group, with him
   The facts are stated in the opinion of the Court. guaranteeing the turnover to them of a certain property
located in Antipolo City belonging to ICS Corporation in
BERSAMIN, J.: exchange for their desistance. They acceded and executed
An attorney who wittingly represents and serves the affidavit of desistance he prepared, and in turn they
conflicting interests may be suspended from the practice of received a deed of assignment covering land registered
law, or even disbarred when circumstances so warrant. under Transfer Certificate of Title No. R-4475 executed by
Antecedents Sison in behalf of ICS Corporation.3
Ferdinand A. Samson has brought this complaint for Samson and his relatives later demanded from Atty. Era
disbarment charging respondent Atty. Edgardo O. Era with that they be given instead a deed of absolute sale to enable
violation of his trust and confidence of a client by them to liquidate the property among themselves. It took
representing the interest of Emilia C. Sison, his present some period of negotiations between them and Atty. Era
client, in a manner that blatantly conflicted with his before the latter delivered to them on November 27, 2003
interest. five copies of a deed of absolute sale involving the property.
Samson and his relatives were among the investors who However, Atty. Era told them that whether or not the title
fell prey to the pyramiding scam perpetrated by ICS of the property had been encumbered or free from lien or
Exports, Inc. Exporter, Importer, and Multi-Level defect would no longer be his responsibility. He further told
Marketing Business (ICS Corporation), a corporation them that as far as he was concerned he had already
whose corporate officers were led by Sison. The other accomplished his professional responsibility towards them
officers were Ireneo C. Sison, William C. Sison, Mimosa H. upon the amica-
Zamudio, Mirasol H. Aguilar and Jhun Sison.
Samson engaged Atty. Era to represent and assist him _______________
and his relatives in the criminal prosecution of Sison and 1 Rollo, Vol. I, pp. 9-11.
her group. Pursuant to the engagement, Atty. Era prepared 2 Rollo, Vol. III, p. 4.
the demand letter dated July 19, 2002 demanding the 3 Rollo, Vol. I, pp. 97-99.
return or refund of the money subject of their complaints.
He also pre- 245

244
VOL. 701, JULY 16, 2013 245
244 SUPREME COURT REPORTS ANNOTATED Samson vs. Era
Samson vs. Era
ble settlement of the cases between them and ICS
Corporation.4
pared the complaint-affidavit that Samson signed and
When Samson and his co-complainants verified the title
swore to on July 26, 2002. Subsequently, the complaint-
of the property at the Registry of Deeds and the Assessor’s
affidavit charging Sison and the other corporate officials of
Office of Antipolo City, they were dismayed to learn that
ICS Corporation with several counts of estafa1 was
they could not liquidate the property because it was no
presented to the Office of the City Prosecutor of Quezon
longer registered under the name of ICS Corporation but
City (OCPQC). After the preliminary investigation, the
was already under the name of Bank Wise Inc.5 Upon their
OCPQC formally charged Sison and the others with several
www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 3/14 www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 4/14
4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701 4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701

urging, Atty. Era negotiated as their counsel with ICS the comment to supposedly enable him to collate
Corporation. documents relevant to his comment.11 The Court granted
Due to the silence of Atty. Era for sometime thereafter, his request and allowed him an extension totalling 40 days.
Samson and his group wrote to him on September 8, 2004 But despite the lapse of the extended period, he did not file
to remind him about his guarantee and the promise to his comment.
settle the issues with Sison and her cohorts. But they did On September 27, 2005, Samson reiterated his
not hear from Atty. Era at all.6 complaint for disbarment against Atty. Era.12
During the hearings in the RTC, Atty. Era did not By its resolution dated March 1, 2006,13 the Court
anymore appear for Samson and his group. This forced required Atty. Era to show cause why he should not be
them to engage another lawyer. They were shocked to find disciplinarily dealt with or held in contempt for such
out later on, however, that Atty. Era had already been failure to submit his comment.
entering his appearance as the counsel for Sison in her In the comment that he subsequently filed on April 11,
other criminal cases in the other branches of the RTC in 2006 in the Office of the Bar Confidant,14 Atty. Era alleged
Quezon City involving the same pyramiding scam that she that the conclusion on April 23, 2002 of the compromise
and her ICS Corporation had perpetrated.7 In this regard, settlement between Samson and his group, on one hand,
they established Atty. Era’s legal representation of Sison and Sison and her ICS Corporation, on the other, had
by submitting several certified copies of the minutes of the terminated the lawyer-client relationship between him and
proceedings in the criminal cases involving Sison and her Samson and his group; and that on September 1, 2003, he
group issued by Branch 102 and Branch 220 of the RTC in had been appointed as counsel de officio for Sison by
Quezon City showing that Atty. Era had appeared as the Branch 102 of the RTC in Quezon City only for purposes of
counsel of Sison in the cases for estafa pending and being her arraignment.
tried in said courts.8 They also submitted a certification
issued on November 3, 2004 indicating that Atty. Era had _______________
visited Sison, an inmate in the Female Dormitory in 9  Id., at pp. 18-30.
10 Id., at pp. 1-3.
_______________ 11 Id., at pp. 32-37.
4 Id., at p. 2. 12 Id., at pp. 62-63.
5 Id., at p. 96. 13 Id., at p. 79.
6 Id., at p. 16. 14 Id., at pp. 80-82.
7 Id., at pp. 65-71.
8 Id., at pp. 23-30. 247

246
VOL. 701, JULY 16, 2013 247
Samson vs. Era
246 SUPREME COURT REPORTS ANNOTATED
Samson vs. Era On July 17, 2006, the Court referred the case to the
Integrated Bar of the Philippines (IBP) for investigation,
Camp Karingal, Sikatuna Village, Quezon City as borne report and recommendation.15
out by the blotter logbook of that unit.9 In his report and recommendation dated October 1,
On January 20, 2005, Samson executed an affidavit 2007,16 the Investigating Commissioner of the IBP
alleging the foregoing antecedents, and praying for Atty. Commission on Bar Discipline (IBP-CBD) found Atty. Era
Era’s disbarment on the ground of his violation of the trust, guilty of misconduct for representing conflicting interests,
confidence and respect reposed in him as their counsel.10 for failing to serve his clients with competence and
Upon being required by the Court to comment on the diligence, and for failing to champion his clients’ cause with
complaint against him within 10 days from notice, Atty. wholehearted fidelity, care and devotion.
Era several times sought the extension of his period to file

www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 5/14 www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 6/14

4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701 4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701

The Investigating Commissioner observed that the for reconsideration and affirming Resolution No. XVIII-
evidence did not sustain Atty. Era’s claim that his legal 2007-195.
services as counsel for Samson and his group had The IBP Board of Governors then forwarded the case to
terminated on April 23, 2003 upon the execution of the the Court pursuant to Section 12(b), Rule 139-B of the
compromise settlement of the criminal cases; that he even Rules of Court.21
admitted during the mandatory conference that there was On October 17, 2012, Atty. Era filed a Manifestation and
no formal termination of his legal services;17 that his Motion (With Leave of Court).22 However, on November 26,
professional obligation towards Samson and his group as 2012, the Court merely noted the manifestation, and
his clients did not end upon execution of the settlement denied the motion for its lack of merit.23
agreement, because he remained duty-bound to see to it Ruling
that the settlement was duly implemented; that he also We affirm the findings of the IBP.
had the obligation to appear in the criminal cases until In his petition for disbarment, Samson charged Atty.
their termination; and that his acceptance of the Era with violating Canon 15 of the Code of Professional
engagement to appear in behalf of Sison invited suspicion Responsi-
of his double-dealing and unfaithfulness.
The Investigating Commissioner recommended that _______________
Atty. Era be suspended from the practice of law for six 18 Id., at p. 15.
months, viz.: 19 Id., at p. 1.

From the foregoing, it is clear that respondent is guilty of 20 Id., at p. 49.

misconduct for representing conflicting interests, failing to 21  Section 12(b). If the Board, by the vote of a majority of its total
serve his client, complainant herein, with competence and membership, determines that the respondent should be suspended from
diligence and champion the latter’s cause with the practice of law or disbarred, it shall issue a resolution setting forth its
wholehearted fidelity, care and devotion. It is respectfully findings and recommendations which, together with the whole record of
recommended that respondent be SUS- the case, shall forthwith be transmitted to the Supreme Court for final
action.
22 Temporary Rollo, pp. 2-14.
_______________
15 Id., at p. 117.
23 Rollo, Vol. III, pp. 67-68.

16 Rollo, Vol. III, pp. 2-15.

249
17 Id., at p. 9.

248 VOL. 701, JULY 16, 2013 249

Samson vs. Era
248 SUPREME COURT REPORTS ANNOTATED
Samson vs. Era bility for representing conflicting interests by accepting
the responsibility of representing Sison in the cases similar
PENDED from the practice of law for a period of six (6) to those in which he had undertaken to represent Samson
months and WARNED that a repetition of the same or and his group, notwithstanding that Sison was the very
similar act would merit a more severe penalty.18 same person whom Samson and his group had accused
with Atty. Era’s legal assistance. He had drafted the
In Resolution No. XVIII-2007-195 passed on October 19,
demand letters and the complaint-affidavit that became the
2007,19 the IBP Board of Governors adopted and approved
bases for the filing of the estafa charges against Sison and
the report and recommendation of the Investigating
the others in the RTC in Quezon City.
Commissioner of the IBP-CBD, with the modification that
Atty. Era’s contention that the lawyer-client relationship
Atty. Era be suspended from the practice of law for two
ended when Samson and his group entered into the
years.
compromise settlement with Sison on April 23, 2002 was
On June 9, 2012, the IBP Board of Governors passed
unwarranted. The lawyer-client relationship did not
Resolution No. XX-2012-180,20 denying Atty. Era’s motion
www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 7/14 www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 8/14
4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701 4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701

terminate as of then, for the fact remained that he still acceptance of the new retainer will require the attorney to
needed to oversee the implementation of the settlement as perform an act which will injuriously affect his first client in
well as to proceed with the criminal cases until they were any matter in which he represents him and also whether he
dismissed or otherwise concluded by the trial court. It is will be called upon in his new relation to use against his
also relevant to indicate that the execution of a compromise first client any knowledge acquired through their
settlement in the criminal cases did not ipso facto cause the connection. Another test of the inconsistency of interests is
termination of the cases not only because the approval of whether the acceptance of a new relation will prevent an
the compromise by the trial court was still required, but attorney from the full discharge of his duty of undivided
also because the compromise would have applied only to fidelity and loyalty to his client or invite suspicion of
the civil aspect, and excluded the criminal aspect pursuant unfaithfulness or double dealing in the performance
to Article 2034 of the Civil Code.24 thereof.28
Rule 15.03, Canon 15 of the Code of Professional
Responsibility provides that: “A lawyer shall not represent The prohibition against conflict of interest rests on five
conflicting interests except by written consent of all rationales, rendered as follows:
concerned given after a full disclosure of the facts.” Atty.
x  x  x. First, the law seeks to assure clients that their
Era thus owed to Samson and his group entire devotion to
lawyers will represent them with undivided loyalty. A client
their genuine interest, and warm zeal in the maintenance
is entitled to be represented by a lawyer whom
and defense of their rights.25 He was expected to exert his
best efforts and ability
_______________
26 Reyes v. Vitan, A.C. No. 5835, April 15, 2005, 456 SCRA 87, 90.
_______________ 27 A.C. No. 5804, July 1, 2003, 405 SCRA 220.
24  The Civil Code states in Article 2034 that: “There may be a 28 Id., at p. 223.
compromise upon the civil liability arising from an offense; but such
compromise shall not extinguish the public action for the imposition of the 251

legal penalty. (1813).”

25 Agpalo, R., Legal Ethics, 1989, 4th Edition, p. 157. VOL. 701, JULY 16, 2013 251

250 Samson vs. Era

the client can trust. Instilling such confidence is an

250 SUPREME COURT REPORTS ANNOTATED objective important in itself. x x x.
Samson vs. Era Second, the prohibition against conflicts of interest seeks
to enhance the effectiveness of legal representation. To the
extent that a conflict of interest undermines the
to preserve the clients’ cause, for the unwavering loyalty
independence of the lawyer’s professional judgment or
displayed to his clients likewise served the ends of justice.26
inhibits a lawyer from working with appropriate vigor in
In Hornilla v. Atty. Salunat,27 the Court discussed the
the client’s behalf, the client’s expectation of effective
concept of conflict of interest in this wise:
representation x x x could be compromised.
There is conflict of interest when a lawyer represents Third, a client has a legal right to have the lawyer
inconsistent interests of two or more opposing parties. The safeguard the client’s confidential information xxx.
test is “whether or not in behalf of one client, it is the Preventing use of confidential client information against the
lawyer’s duty to fight for an issue or claim, but it is his duty interests of the client, either to benefit the lawyer’s personal
to oppose it for the other client. In brief, if he argues for one interest, in aid of some other client, or to foster an assumed
client, this argument will be opposed by him when he public purpose is facilitated through conflicts rules that
argues for the other client.” This rule covers not only cases reduce the opportunity for such abuse.
in which confidential communications have been confided, Fourth, conflicts rules help ensure that lawyers will not
but also those in which no confidence has been bestowed or exploit clients, such as by inducing a client to make a gift to
will be used. Also, there is conflict of interests if the the lawyer xxx.
www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 9/14 www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 10/14
4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701 4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701

Finally, some conflict-of-interest rules protect interests of matter in which the lawyer previously represented the
the legal system in obtaining adequate presentations to client. Nor should the lawyer disclose or use any of the
tribunals. In the absence of such rules, for example, a client’s confidences acquired in the previous relation.34 In
lawyer might appear on both sides of the litigation, this regard, Canon 17 of the Code of
complicating the process of taking proof and compromise
adversary argumentation x x x.29 _______________
30 Heirs of Lydio “Jerry” Falame v. Baguio, A.C. No. 6876, March 7,
The rule prohibiting conflict of interest was fashioned to
2008, 548 SCRA 1, 13.
prevent situations wherein a lawyer would be representing
31 Kauffman, K. D., Legal Ethics, Delmar Learning, 2004, pp. 174-175,
a client whose interest is directly adverse to any of his
207.
present or former clients. In the same way, a lawyer may
32  Hilado v. David, 84 Phil. 569, 579 (1949) cited in Quiambao v.
only be allowed to represent a client involving the same or
Bamba, A.C. No. 6708, August 25, 2005, 468 SCRA 1, 9-10.
a substantially related matter that is materially adverse to
the former client only if the former client consents to it 33 Perez v. De la Torre, A.C. No. 6160, March 30, 2006, 485 SCRA 547,

after consulta- 551.

34  Agpalo, The Code of Professional Responsibility for Lawyers, 1991,
1st Edition, p. 167, citing Nombrado v. Hernandez, Adm. Case No. 555,
_______________
November 25, 1968, 26 SCRA 13, Natam v. Capule, 91 Phil.
29 Law Governing Lawyers, Restatement of the Law Third, Volume 2,
2000 Edition, American Law Institute, Washington D.C., §121. 253

252
VOL. 701, JULY 16, 2013 253
252 SUPREME COURT REPORTS ANNOTATED Samson vs. Era
Samson vs. Era
Professional Responsibility expressly declares that: “A
lawyer owes fidelity to the cause of his client and he shall
tion.30 The rule is grounded in the fiduciary obligation of
be mindful of the trust and confidence reposed in him.”
loyalty.31 Throughout the course of a lawyer-client
The lawyer’s highest and most unquestioned duty is to
relationship, the lawyer learns all the facts connected with
protect the client at all hazards and costs even to himself.35
the client’s case, including the weak and strong points of
The protection given to the client is perpetual and does not
the case. Knowledge and information gathered in the
cease with the termination of the litigation, nor is it
course of the relationship must be treated as sacred and
affected by the client’s ceasing to employ the attorney and
guarded with care. It behooves lawyers not only to keep
retaining another, or by any other change of relation
inviolate the client’s confidence, but also to avoid the
between them. It even survives the death of the client.36
appearance of treachery and double-dealing, for only then
In the absence of the express consent from Samson and
can litigants be encouraged to entrust their secrets to their
his group after full disclosure to them of the conflict of
lawyers, which is paramount in the administration of
interest, therefore, the most ethical thing for Atty. Era to
justice.32 The nature of that relationship is, therefore, one
have done was either to outrightly decline representing and
of trust and confidence of the highest degree.33
entering his appearance as counsel for Sison, or to advice
Contrary to Atty. Era’s ill-conceived attempt to explain
Sison to engage another lawyer for herself. Unfortunately,
his disloyalty to Samson and his group, the termination of
he did neither, and should now suffer the proper sanction.
the attorney-client relationship does not justify a lawyer to
WHEREFORE, the Court FINDS and
represent an interest adverse to or in conflict with that of
PRONOUNCES Atty. EDGARDO O. ERA guilty of
the former client. The spirit behind this rule is that the
violating Rule 15.03 of Canon 15, and Canon 17 of the Code
client’s confidence once given should not be stripped by the
of Professional Responsibility; and SUSPENDS him from
mere expiration of the professional employment. Even after
the practice of law for two years effective upon his receipt
the severance of the relation, a lawyer should not do
anything that will injuriously affect his former client in any
www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 11/14 www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 12/14
4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701 4/21/2020 SUPREME COURT REPORTS ANNOTATED VOLUME 701

of this decision, with a warning that his commission of a

similar offense will be dealt with more severely. © Copyright 2020 Central Book Supply, Inc. All rights reserved.
Let copies of this decision be included in the personal
record of Atty. EDGARDO O. ERA and entered in his file
in the Office of the Bar Confidant.

_______________
640 (1952), San Jose v. Cruz, 57 Phil. 792 (1933) and Hilado v. David,
84 Phil. 569 (1949).
35 Id., at p. 199, citing Watkins v. Sedberry, 261 U.S. 571, 67 L. ed. 802
(1923).
36 Bun Siong Yao v. Aurelio, A.C. No. 7023, March 30, 2006, 485 SCRA
553, 560.

254

254 SUPREME COURT REPORTS ANNOTATED

Samson vs. Era

Let copies of this decision be disseminated to all lower

courts by the Office of the Court Administrator, as well as
to the Integrated Bar of the Philippines for its guidance.
SO ORDERED.

Sereno (CJ.), Carpio, Velasco, Jr., Leonardo-De Castro,

Peralta, Del Castillo, Abad, Villarama, Jr., Perez, Mendoza,
Reyes, Perlas-Bernabe and Leonen, JJ., concur.
Brion, J., On Leave.

Atty. Edgardo O. Era suspended from practice of law for

two (2) years for violation of Rule 15.03 of Canon 15, and
Canon 17 of Code of Professional Responsibility.

Notes.―Absence of monetary consideration does not

exempt lawyers from complying with the prohibition
against pursuing cases with conflicting interests. (Castro-
Justo vs. Galing, 660 SCRA 140 [2011])
A lawyer shall not represent conflicting interests except
by written consent of all concerned given after a full
disclosure of facts. (Catalan, Jr. vs. Silvosa, 677 SCRA 352
[2012])
――o0o―― 

www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 13/14 www.central.com.ph/sfsreader/session/00000171988510fd083beb8f003600fb002c009e/t/?o=False 14/14