The Supreme Court disbarred Atty. Roy Prule Ediza for grave misconduct and willful disobedience to lawful court orders. This decision underscores the high ethical standards required of lawyers and the severe consequences of disregarding judicial directives. The Court emphasized that the practice of law is a privilege burdened with public interest, demanding unwavering adherence to legal and ethical standards.

When Defiance Leads to Disbarment: The Ediza Case

This case revolves around the administrative complaint filed by spouses Nemesio and Caridad Floran against Atty. Roy Prule Ediza, accusing him of deceit and professional misconduct. The dispute originated from a 3.5525-hectare parcel of unregistered land in Misamis Oriental, which was to be transferred to the complainants. Atty. Ediza’s actions, including deceiving the Florans into signing a deed of sale transferring a portion of their land to him and misappropriating proceeds from the land sale, led to the initial suspension of Atty. Ediza from the practice of law for six months.

Following the Court’s decision on October 19, 2011, which included the suspension and directives for restitution, Atty. Ediza repeatedly failed to comply with the Court’s orders. He did not return the documents he had misled the complainants into signing, nor did he pay the ordered sum of P125,463.38 with legal interest. Furthermore, he failed to submit certifications from the Integrated Bar of the Philippines (IBP) and the Office of the Executive Judge, confirming his desistance from the practice of law during his suspension period. This pattern of non-compliance prompted the Court to issue multiple resolutions, demanding compliance and threatening more severe penalties.

Atty. Ediza’s responses to these resolutions further aggravated his situation. He claimed ignorance regarding the documents in question, alleged the existence of newly discovered evidence, and sought to stay the execution of the Court’s decision. He also reported compliance with the suspension order without providing the necessary certifications. The Supreme Court viewed these actions as a deliberate attempt to defy its authority and obstruct the administration of justice. This defiance prompted the Court to consider the gravity of Atty. Ediza’s misconduct in light of the ethical standards required of legal professionals. The Court quoted Rule 12.04 of Canon 12 of the Code of Professional Responsibility:

CANON 12

A LAWYER SHALL EXERT EVERY EFFORT AND CONSIDER IT HIS DUTY TO ASSIST IN THE SPEEDY AND EFFICIENT ADMINISTRATION OF JUSTICE.

x x x x

Rule 12.04 – A lawyer shall not unduly delay a case, impede the execution of a judgment or misuse Court processes.

The Court highlighted the importance of a lawyer’s duty to obey court orders and processes promptly and without resistance. Atty. Ediza’s previous suspension for violating the Code of Professional Responsibility did not deter him from further misconduct. This continued defiance demonstrated a lack of fitness to remain in the legal profession. The Supreme Court cited Section 5(5), Article VIII of the Constitution, which recognizes the disciplinary authority of the Court over members of the Bar. The Court also referenced Section 27, Rule 138 of the Rules of Court, which provides grounds for disbarment or suspension, including willful disobedience of any lawful order of a superior court:

Section 27. Disbarment or suspension of attorneys by Supreme Court; grounds therefor. — A member of the bar may be disbarred or suspended from his office as attorney by the Supreme Court for any deceit, malpractice, or other gross misconduct in such office, grossly immoral conduct, or by reason of his conviction of a crime involving moral turpitude, or for any violation of the oath which he is required to take before admission to practice, or for a willful disobedience of any lawful order of a superior court, or for corruptly or willfully appearing as an attorney for a party to a case without authority so to do. The practice of soliciting cases at law for the purpose of gain, either personally or through paid agents or brokers, constitutes malpractice.

The Court noted that while the power to disbar is exercised cautiously, Atty. Ediza’s persistent non-compliance and defiance warranted the ultimate disciplinary sanction. The practice of law is a privilege conditioned on adherence to high standards of morality and faithful compliance with the rules of the legal profession. Atty. Ediza’s conduct demonstrated a clear unfitness to remain in the legal profession, leading to his disbarment.

FAQs

What was the key issue in this case?	The central issue was whether Atty. Ediza’s repeated failure to comply with court orders, coupled with his prior ethical violations, warranted disbarment. His willful disobedience and grave misconduct were the primary considerations.
What specific actions led to Atty. Ediza’s disbarment?	His disbarment stemmed from his failure to return documents, pay restitution to the complainants, submit required certifications, and his overall defiance of multiple court orders. His previous suspension also contributed to the decision.
What is the significance of Canon 12, Rule 12.04 of the Code of Professional Responsibility?	This rule emphasizes a lawyer’s duty to assist in the speedy and efficient administration of justice. It prohibits lawyers from unduly delaying cases, impeding the execution of judgments, or misusing court processes, all of which Atty. Ediza was found to have violated.
What does the Supreme Court consider when deciding whether to disbar an attorney?	The Court considers the attorney’s misconduct, character, and standing as a legal professional and officer of the Court. Disbarment is reserved for cases of serious misconduct that significantly impact the attorney’s integrity and the public’s trust.
Why is compliance with court orders so important for attorneys?	Compliance with court orders is crucial because attorneys are officers of the court and play a vital role in the administration of justice. Disobedience undermines the authority of the courts and the integrity of the legal system.
What does it mean for an attorney to be ‘stricken off the Roll of Attorneys’?	Being ‘stricken off the Roll of Attorneys’ means that the attorney’s name is permanently removed from the list of lawyers authorized to practice law in the Philippines. It effectively ends their legal career.
What constitutional provision grants the Supreme Court disciplinary authority over lawyers?	Section 5(5), Article VIII of the Constitution recognizes the disciplinary authority of the Supreme Court over members of the Bar. This provision allows the Court to oversee and regulate the conduct of lawyers.
Can a disbarred attorney ever be reinstated to the practice of law?	Reinstatement is possible but requires a rigorous process, including demonstrating rehabilitation, remorse, and fitness to practice law. The attorney must petition the Supreme Court for reinstatement.

The disbarment of Atty. Ediza serves as a stark reminder of the ethical responsibilities that come with the privilege of practicing law. Lawyers must uphold the law, respect the courts, and act with integrity in all their professional dealings. Failure to do so can result in severe consequences, including the loss of their license to practice.

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: NEMESIO FLORAN AND CARIDAD FLORAN, COMPLAINANTS, VS. ATTY. ROY PRULE EDIZA, RESPONDENT., AC No. 5325, February 09, 2016