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Lawyer-client relationship In the case of MA. LUISA HADJULA vs. ATTY. ROCELES F. MADIANDA, A.C. No. 6711, July 3, 2007, the Supreme Court reprimanded and admonished the respondent lawyer to be circumspect in her handling of information acquired as a result of a lawyer-client relationship. Let me digest the case below for legal research purposes. In 2002, the complainant charged the respondent lawyer with violation of Article 209 (Betrayal of Trust by an Attorney/Revelation of Secrets) of the Revised Penal Code and Canon Nos. 15.02 and 21.02 of the Code of Professional Responsibility. The complainant alleged that she and respondent used to be friends as they both worked at the Bureau of Fire Protection (BFP) whereat respondent was the Chief Legal Officer while she was the Chief Nurse of the Medical, Dental and Nursing Services. Complainant claimed that, sometime in 1998, she approached respondent for some legal advice. Complainant further alleged that, in the course of their conversation which was supposed to be kept confidential, she disclosed personal secrets and produced copies of a marriage contract, a birth certificate and a baptismal certificate, only to be informed later by the respondent that she (respondent) would refer the matter to a lawyer friend. It was malicious, so complainant states, of respondent to have refused handling her case only after she had already heard her secrets. The complainant averred that her friendship with respondent soured after her filing, in the later part of 2000, of criminal and disciplinary actions against the latter. What, per complainant’s account, precipitated the filing was when respondent, then a member of the BFP promotion board, demanded a cellular phone in exchange for the complainant’s promotion. According to complainant, respondent, in retaliation to the filing of the aforesaid actions, filed a COUNTER COMPLAINT with the Ombudsman charging her (complainant) with violation of Section 3(a) of Republic Act No. 3019, falsification of public documents and immorality, the last two charges being based on the disclosures complainant earlier made to respondent. And also on the basis of the same disclosures, complainant further stated, a Page 1 of 4

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Lawyer-client relationshipIn the case of MA. LUISA HADJULA vs. ATTY. R!"L"S #. MADIA$DA% A.!. $o. &'((% J)ly*% +,,'% the S)pre-e !o)rt repri-an.e. an. a.-onishe. the respon.ent lawyer to /e circ)-spectin her han.lin0 of infor-ation ac1)ire. as a res)lt of a lawyer-client relationship. Let -e .i0estthe case /elow for le0al research p)rposes.In +,,+% the co-plainant char0e. the respon.ent lawyer with violation of Article +,2 34etrayal ofTr)st /y an Attorney5Revelation of Secrets6 of the Revise. 7enal !o.e an. !anon $os. (8.,+ an.+(.,+ of the !o.e of 7rofessional Responsi/ility.The co-plainant alle0e. that she an. respon.ent )se. to /e frien.s as they /oth wor9e. at the4)rea) of #ire 7rotection 34#76 whereat respon.ent was the !hief Le0al fficer while she was the!hief $)rse of the Me.ical% Dental an. $)rsin0 Services. !o-plainant clai-e. that% so-eti-e in(22:% she approache. respon.ent for so-e le0al a.vice. !o-plainant f)rther alle0e. that% in theco)rse of their conversation which was s)ppose. to /e 9ept confi.ential% she .isclose. personalsecrets an. pro.)ce. copies of a -arria0e contract% a /irth certificate an. a /aptis-al certificate%onlyto/einfor-e.later/ytherespon.ent that she3respon.ent6wo)l.referthe-attertoalawyer frien.. It was -alicio)s% so co-plainant states% of respon.ent to have ref)se. han.lin0 hercase only after she ha. alrea.y hear. her secrets.The co-plainant averre. that her frien.ship with respon.ent so)re. after her filin0% in the laterpart of +,,,% of cri-inal an..isciplinaryactions a0ainst thelatter. ;hat% per co-plainantIT-!M7LAI$Tforreasonthat shenever ;ASMY !LI"$Tnorweeverha.anyLA;Y"R-!LI"$TR"LATI$SHI7 that evere=iste.eversincean.that nevero/taine.anyle0al a.vicefro--ere0ar.in0her7"RS$AL 7R4L"MSor7"RS$AL S"!R"TS. Sheli9ewise never .elivere. to -e le0al .oc)-ents -)ch -ore tol. -e so-e confi.ential infor-ationor secrets. That is /eca)se I never entertain L"AAL BU"RI"S or !$SULTATI$ re0ar.in07"RS$AL MATT"RS since I 9now as a LA;Y"R of the 4)rea) of #ire 7rotection that I a-not allowe. to privately practice law an. it -i0ht also res)lt to !$#LI!T # I$T"R"ST. As a-atter of fact% whenever there will /e 7"RS$AL MATT"RS referre. to -e% I C)st referre. the-7a0e ( of *to private law practitioners an. never entertain the sa-e% $R listen to their stories or e=a-ine oraccept any .oc)-ent.2. I specifically .eny the alle0ation of #5SU7T. MA. LUISA !. HADJULA in para0raph : of herA##IDA>IT-!M7LAI$T% the tr)th of the -atter is that her ILLI!IT R"LATI$SHI7 an. herille0al an.)nlawf)l activitiesare9nowninthe4)rea)of#ire7rotectionsinceshealsofile.!HILDSU77RTcasea0ainst her lover Dwhereshehasachil.D.Moreover% thealle0e.D!UM"$TS she p)rporte.ly have shown to -e so-eti-e in (22:% are all part of p)/lic recor.sD.#)rther-ore%#5SU7T. MA. LUISA !.HADJULA%is filin0 the instant case C)st to 0et evenwith -e or to force -e to settle an. with.raw the !AS"S I #IL"D AAAI$ST H"R since she9nows that she will certainly /e DISMISS"D #RM S"R>I!"% R"M>"D #RM TH" 7R!RLL an. !RIMI$ALLY!$>I!T"D of her ILLI!IT% IMMRAL% ILL"AAL an.U$LA;#UL A!TS.As it were% co-plainant went to respon.ent% a lawyer who inci.entally was also then a frien.% to/are what she consi.ere. personal secrets an. sensitive .oc)-ents for the p)rpose of o/tainin0le0al a.vice an. assistance. The -o-ent co-plainant approache. the then receptive respon.ent tosee9 le0al a.vice% a verita/le lawyer-client relationship evolve. /etween the two. S)chrelationshipi-poses )ponthe lawyer certainrestrictions circ)-scri/e./ythe ethics of theprofession. A-on0 the /)r.ens of the relationship is that which enCoins the lawyer% respon.ent inthis instance% to 9eep inviolate confi.ential infor-ation ac1)ire. or reveale. .)rin0 le0alcons)ltations. The fact that one is% at the en. of the .ay% not incline. to han.le the client