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Legal Ethics
Angeles v. Uy
A.C. No. 5019. April 6, 2000
In a Criminal case, a certain Norma Trajano alleged that she paid 20k to private complainant Del
Rosario and the balance of 16.5k was delivered to Atty. Uy, the lawyer of private complainant in
the said case.
Complainant Del Rosario manifested that she did not receive the 16.5k pesos that was paid to
Atty. Uy.
Atty. Uy however argued that his client was the one that did not accept the money since they
wanted to receive the whole amount. But such an assertion was belied when Del Rosario
manifested her willingness to accept the money.
Atty. Uy alleged that the amount was safely in his office in the same building. As such,
the proceedings were suspended in order for Uy to get the money from his office. Yet, Atty. Uy
never returned hence the administrative case against him.
In his comment, Atty. Uy contends that he kept the money in his office because it was the wish
of his client. He allegedly informed them of such money and tried to give it to them but they
insisted that he retain it in order for them to not spend it.
The Office of the Bar Confidant recommended that Atty. Uy be suspended for one month. It was
decided that the complainants side of the story had more merit.
Issue: WON Uy is guilty of violating Canon 16 of the CPR
The Court agreed with the Office of the Bar Confidant.
The relationship between a lawyer and a client is highly fiduciary. It requires a high degree of
fidelity and good faith. It is designed to remove all such temptation and to prevent everything of
that kind from being done for the protection of the client.
Canon 16 of the CPR provides that a lawyer shall hold in trust all moneys and properties of
his client that may come into his possession.
Furthermore, Rule 16.01 states that a lawyer shall account for all the money or property
collected or received for or from the client.
Respondent failed to promptly report and account for the 16.5k he had received fromTrajano on
behalf of his client.

If it were true that Del Rosario was informed about the payment and that she entrusted it to Atty.
Uy, she would have known his whereabouts. That she did not know it showed falsity of the
In Aya v. Bigornia, the Court ruled that money collected by a lawyer in favor of his clients must
be immediately turned over to them.
In Daroy v. Legaspi, the Court held that lawyers are bound to promptly account for money or
property received by them on behalf of their clients and failure to do so constitutes professional
Verily, the question is not necessarily whether the rights of the clients have been prejudiced, but
whether the lawyer has adhered to the ethical standards of the bar.
In this light, the Court must stress that it has the duty to look into dealings between attorneys
and their clients and to guard the latter from any undue consequences resulting from a situation
in which they may stand unequal.
In the present case, the records merely show that respondent did not promptly report that he
received money on behalf of his client. There is no clear evidence of misappropriation. Under
the circumstances, Atty. Uy should be suspended for only one month.