Consorcia Rollon vs Atty. Camilo Naraval

written by Howard

A.C. No. 6424 – 493 Phil. 24 – 452 SCRA 675 – Legal Ethics – Lawyers must only undertake legal services they can deliver

In October 2000, Consorcia Rollon sought the assistance of Atty. Camilo Naraval in a collection of sum of money case filed against her. Atty. Naraval agreed to be his lawyer and he collected Php8k as acceptance fee. However, Atty. Naraval did nothing in the case of Rollon. He failed to update her of any development. When Rollon made follow-ups, Atty. Naraval kept on telling her that he is so busy with his other cases. In November 2001, Rollon decided to terminate Atty. Naraval’s legal services. She then demanded for the return of her money as well as the documents she entrusted to him. However, Atty. Naraval failed to issue a refund (he even told her he has no money) nor did he return her documents. Despite several demands, Atty. Naraval failed to return Rollon’s money and documents.

ISSUE: Whether or not Atty. Naraval should be disciplined.

HELD: Yes. Every case accepted by a lawyer deserves full attention, diligence, skill and competence, regardless of importance. A lawyer shall keep his client informed of the status of his case and shall respond within a reasonable time to the client’s request for information. Hence, practicing lawyers may accept only as many cases as they can efficiently handle. Otherwise, their clients would be prejudiced. Once lawyers agree to handle a case, they should undertake the task with dedication and care. If they do any less, then they fail their lawyer’s oath.

Atty. Naraval’s continuous inaction despite repeated followups from her reveals his cavalier attitude and appalling indifference toward his client’s cause, in brazen disregard of his duties as a lawyer. Despite her repeated demands, he also unjustifiably failed to return to her the files of the case that had been entrusted to him. To top it all, he kept the money she had likewise entrusted to him. Not only that, it would appear that when Atty. Naraval accepted the case, it was already decided against Rollon and the decision was already final. Atty. Naraval failed to inform Rollon on that. Atty. Naraval was suspended for two years.

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