The Supreme Court in Laurence D. Punla and Marilyn Santos v. Atty. Eleonor Maravilla-Ona, found Atty. Eleonor Maravilla-Ona guilty of violating the Code of Professional Responsibility for neglecting her clients’ interests and failing to return their money. Despite already being disbarred in a previous case, the Court fined her P40,000 and ordered her to return P350,000 to the complainants with interest. This decision underscores the Court’s commitment to upholding ethical standards in the legal profession, even when an attorney has already faced the ultimate penalty.

Justice Denied: Did Atty. Maravilla-Ona’s Actions Warrant Disbarment Despite Her Prior Removal from the Bar?

The case began with a complaint filed by Laurence D. Punla and Marilyn Santos against Atty. Eleonor Maravilla-Ona, alleging that she violated her lawyer’s oath by neglecting their interests. The complainants had engaged Atty. Maravilla-Ona to handle two annulment cases, paying her P350,000 with the understanding that the cases would be resolved within six months. However, Atty. Maravilla-Ona failed to take any action and ignored the complainants’ follow-ups, leading them to demand a refund. Despite receiving a demand letter, she did not return the money. The Integrated Bar of the Philippines (IBP) investigated the matter, finding Atty. Maravilla-Ona guilty of violating Canons 17 and 18 of the Code of Professional Responsibility, which require lawyers to be faithful to their clients’ cause and to serve them with competence and diligence. In addition, the IBP noted that Atty. Maravilla-Ona had several other pending administrative cases against her.

The Investigating Commissioner recommended that Atty. Maravilla-Ona be disbarred and ordered to pay the complainants P350,000 with legal interest. The IBP Board of Governors adopted this recommendation. The Supreme Court, in its decision, acknowledged the IBP’s findings but modified the penalty due to Atty. Maravilla-Ona’s prior disbarment. The Court cited Rule 138, Sec. 27 of the Rules of Court, which outlines the grounds for disbarment or suspension, including deceit, malpractice, gross misconduct, and violation of the lawyer’s oath.

The Supreme Court emphasized the importance of a lawyer’s duty to serve clients with competence and zeal, especially when a fee has been accepted. The Court quoted Canon 17 and 18 of the Code of Professional Responsibility:

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.

CANON 18 – A lawyer shall serve his client with competence and diligence.

The Court also reiterated that a lawyer’s failure to return money held for a client upon demand raises a presumption of misappropriation, violating the trust placed in them. The Court also addressed the issue of the multiple cases filed against Atty. Maravilla-Ona, including the previous disbarment case of Suarez v. Maravilla-Ona, where she was disbarred for similar misconduct and for disobeying orders from the IBP. In that case, the court stated that her refusal to obey the IBP’s orders was “blatant disrespect” towards the organization and “conduct unbecoming of a lawyer.” The Supreme Court in Suarez v. Maravilla-Ona, noted the respondent’s repeated violations, stating:

Clearly, Atty. Maravilla-Ona exhibits the habit of violating her oath as a lawyer and the Code [of Professional Responsibility], as well as defying the processes of the IBP. The Court cannot allow her blatant disregard of the Code [of Professional Responsibility] and her sworn duty as a member of the Bar to continue. She had been warned that a similar violation [would] merit a more severe penalty, and yet, her reprehensible conduct has, again, brought embarrassment and dishonor to the legal profession.

Despite acknowledging that Atty. Maravilla-Ona’s actions would typically warrant disbarment, the Court declined to impose a second disbarment, stating that Philippine jurisdiction does not allow for “double disbarment.” Instead, the Court fined her P40,000 and ordered her to pay the complainants P350,000 with interest. Justice Leonen wrote a separate opinion, concurring with the findings but arguing that disbarment should still be imposed for recording purposes and to emphasize the severity of the misconduct, even if it cannot be practically enforced.

This case highlights the serious consequences that lawyers face when they neglect their duties to their clients. Even though Atty. Maravilla-Ona was already disbarred, the Court still imposed additional penalties to underscore the gravity of her misconduct. This decision serves as a reminder to all lawyers of their ethical obligations and the importance of upholding the integrity of the legal profession. The court recognized the need for appropriate sanctions to ensure that lawyers adhere to the highest standards of conduct and to protect the public from unethical practices. Moreover, this case underscores the importance of accountability within the legal profession and serves as a reminder that disciplinary measures will be taken against those who fail to uphold their ethical obligations.

The Supreme Court’s ruling also addresses the calculation of interest on monetary awards, referencing the case of Nacar v. Gallery Frames. This case provides guidelines for determining the applicable interest rates and the periods during which they apply. The decision ensures that the complainants are adequately compensated for the financial losses they incurred as a result of Atty. Maravilla-Ona’s misconduct.

FAQs

What was the key issue in this case?	The key issue was whether Atty. Eleonor Maravilla-Ona violated the Code of Professional Responsibility by neglecting her clients’ interests and failing to return their money, and what the appropriate penalty should be, considering her prior disbarment.
What did the complainants allege against Atty. Maravilla-Ona?	The complainants alleged that they paid Atty. Maravilla-Ona P350,000 to handle two annulment cases, but she failed to take any action and did not refund the money when they demanded it.
What did the IBP find in this case?	The IBP found Atty. Maravilla-Ona guilty of violating Canons 17 and 18 of the Code of Professional Responsibility, which require lawyers to be faithful to their clients’ cause and to serve them with competence and diligence.
Why didn’t the Supreme Court disbar Atty. Maravilla-Ona again?	The Supreme Court stated that Philippine jurisdiction does not allow for “double disbarment,” as Atty. Maravilla-Ona had already been disbarred in a previous case.
What was the penalty imposed by the Supreme Court?	The Supreme Court fined Atty. Maravilla-Ona P40,000 and ordered her to pay the complainants P350,000 with 12% interest from the date of demand until June 30, 2013, and 6% per annum from July 1, 2013, until full payment.
What is the significance of Canon 17 of the Code of Professional Responsibility?	Canon 17 states that a lawyer owes fidelity to the cause of their client and must be mindful of the trust and confidence reposed in them. This means lawyers must act in their clients’ best interests and maintain their trust.
What is the significance of Canon 18 of the Code of Professional Responsibility?	Canon 18 states that a lawyer shall serve their client with competence and diligence. This means lawyers must possess the necessary skills and knowledge to handle a case and must diligently pursue their client’s objectives.
What did Justice Leonen argue in his separate opinion?	Justice Leonen argued that disbarment should still be imposed for recording purposes and to emphasize the severity of the misconduct, even if it cannot be practically enforced due to the prior disbarment.

In conclusion, the Supreme Court’s decision in Punla v. Maravilla-Ona underscores the importance of ethical conduct in the legal profession. While the Court could not impose a second disbarment, the penalties levied against Atty. Maravilla-Ona serve as a strong deterrent against similar misconduct. The ruling reinforces the principle that lawyers must uphold their duties to their clients and maintain the integrity of the legal system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: LAURENCE D. PUNLA AND MARILYN SANTOS, COMPLAINANTS, VS. ATTY. ELEONOR MARAVILLA-ONA, RESPONDENT., A.C. No. 11149, August 15, 2017