1.

Ruthie Lim-Santiago, the daughter of Alfonso Lim and the Special Administratrix of his estate, is
associated with Taggat Industries, Inc., a domestic corporation involved in government timber concessions,
previously led by her father until its sequestration by the PCGG resulted in a cessation of operations.
2. Atty. Carlos Sagucio, the former Personnel Manager and Retained Counsel of Taggat Industries, Inc.,
transitioned to the role of Assistant Provincial Prosecutor in Tuguegarao, Cagayan.
3. Employees of Taggat filed a criminal complaint, alleging that Lim-Santiago, who assumed control of
Taggat following her father's death, unjustly withheld their salaries and wages.
4. In his capacity as Assistant Provincial Prosecutor, Sagucio was tasked with conducting the preliminary
investigation. He addressed the criminal complaint by recommending the filing of 651 Informations for
violating Article 288 in relation to Article 116 of the Labor Code of the Philippines.
5. Lim-Santiago now accuses Sagucio of various violations in connection to these events:
A. Rule 15.03 of the Code of Professional Responsibility, respondent is said to be guilty of
representing conflicting interests. This is based on the respondent's prior roles as the former
Personnel Manager and Retained Counsel of Taggat, which, according to the complainant, should
have inhibited himself from handling the case filed by Taggat employees due to his intimate
knowledge of Taggat's operations.
B. Engaging in the private practice of law while working as a government prosecutor. He received
retainer’s fees which respondent claims to only consultation fees.
6. The complainant is seeking the disbarment of the respondent for alleged violations. The respondent
contends that at the time the criminal complaint was lodged, they had resigned from Taggat over five years
prior. The respondent refutes the complainant's claims, asserting that the dissatisfaction stems from an
unfavorable resolution of the criminal complaint, contrary to the complainant's expectations.
7. The respondent highlights that the complainant did not file a motion to inhibit them from handling the
criminal complaint. The complainant's rationale for not doing so was based on the belief that the respondent
would vindicate her from the charges.
8. During the pendency of this disbarment case, the Regional State Prosecutor reversed and annulled the
resolution and order issued by the respondent, leading to the dismissal of the criminal complaint.

ISSUE:

1. WON being a former lawyer of Taggat conflicts with his role as Assistant Provincial Prosecutor in deciding
the labor case filed against the complainant.
2. WON respondent engaged in the private practice of law while working as a government prosecutor

RULING:
1. The court determined that there was no conflict of interest when the respondent conducted the preliminary
investigation of the 1997 criminal complaint filed by Taggat employees, which centered on issues related to
unpaid wages. It is evident that the respondent had severed ties with Taggat by then, having resigned
around 1992.

To accuse the respondent of representing conflicting interests, it is essential to provide evidence

demonstrating that the respondent utilized confidential information acquired during his previous
employment against Taggat, his former client. The only confirmed involvement the respondent had in the
criminal complaint was conducting the preliminary investigation. Mere facts such as the respondent being
the former Personnel Manager and Retained Counsel of Taggat and the case being labor-related are
insufficient grounds for alleging conflicting interests.
 A lawyer's enduring duty to a former client extends solely to matters handled during the lawyer-client
relationship and does not encompass transactions occurring after the termination of that relationship. The
law intends to bind lawyers with the duty to safeguard the client's interests only in matters they previously
handled for the former client, not for issues arising post-termination. Furthermore, the complainant failed to
present any evidence to substantiate her allegations. Consequently, the respondent is not found guilty of
violating Rule 15.03 of the Code.
2. The Court has broadly defined the practice of law as any activity, whether inside or outside the courtroom,
that involves the application of legal knowledge, procedures, training, and experience. It encompasses acts
characteristic of the legal profession, involving the notice or provision of services requiring some level of
legal knowledge or skill. The argument put forth by the respondent, claiming to have provided intermittent
consultancy services to Taggat without being a retained counsel from 1995 to 1996, is deemed baseless.
The law does not make a distinction between consultancy services and retainer agreements. As long as the
respondent performed tasks typically undertaken by lawyers utilizing legal knowledge, it falls within the
scope of the "practice of law."

However, the respondent acknowledged rendering legal services to the complainant while serving as a
government prosecutor. Even the receipts he signed indicated payments from Taggat as "Retainer’s fee."
Consequently, as correctly asserted by the complainant, the respondent has clearly violated the prohibition
in RA 6713.

In this instance, the respondent's breach of RA 6713 also translates to a violation of Rule 1.01 of Canon 1,
which dictates that "[a] lawyer shall not engage in unlawful, dishonest, immoral, or deceitful conduct."
Admitting to receiving fees for legal services from Taggat while holding a government prosecutor position
constitutes unlawful conduct, thus violating Rule 1.01.

According to Civil Service Law and rules, the penalty for government employees involved in unauthorized
private practice of a profession is a suspension ranging from six months and one day to one year. The court
deems this penalty appropriate for the respondent's violation of Rule 1.01, Canon 1 of the Code of
Professional Responsibility in this case.