No, Louis did not violate the lawyer-client confidentiality as there exists no l

awyer-client relationship between Louis and Manuel. Before lawyer-client privile

ged communication can be asserted, there must (a) exist an attorney and client r
elationship or a kind of consultancy relationship with a prospective client. Tha
t is, legal advice is what is sought; (b) the communication was made by the clie
nt to the lawyer in the course of the lawyer's professional employment; and (c)
the communication must be intended to be confidential. (Uy Chico vs. Union Life
Ass. Society, 29 Phil 163).
Mere meeting of the minds between the lawyer and the client on the case or subje
ct to be handled is sufficient enough to establish commencement of employment, a
nd thus lawyer-client relationship. In the instant case however, the same meetin
g of the minds did not take place. The mere act of soliciting advice from Louis,
which Louis does not view as obtaining professional advice or assistance as the
facts evidently show, is not sufficient enough to establish such relationship,
nor does the act of sending an email confiding the truth about his acts establis
h the same. Absent the attorney and client relationship qualification, there exi
sts no employment of Louis' services as a lawyer and thus any communication betw
een them cannot be deemed confidential.
Assuming arguendo the existence of a client-attorney relationship, without any t
estimony from Manuel if indeed the information divulged was meant to be confiden
tial, as the facts do not show this, it is difficult, if not impossible to deter
mine if there was any violation of the rule on privileged communication. The cou
rt cannot be involved in a guessing game as to the existence of facts which the
complainant must prove (Mercado vs. Vetriolo, 456 SCRA 1). Applying the cited ju
risprudence and absent the testimony of Manuel, there is no case that can be dec
ided on.