SAMUEL B. ARNADO, Complainant, vs. ATTY. HOMOBONO A.

ADAZA, Respondent
A.C. No. 9834, August 26, 2015

FACTS:
Atty. Samuel B. Arnado called the attention of the Court dated March 15, 2013, to the practice of Atty.
Homobono A. Adaza of indicating “MCLE Application for Exemption Under Process” in his pleadings filed
in 2009-2012, and “MCLE Application for Exemption for Reconsideration” in a pleading filed in 2012.
Arnado inquired in the MCLE Office and discovered that Adaza did not comply with three compliance
periods (2001-2010). Furthermore, Adaza’s application for exemption was denied by MCLE Governing
Board.

The Court ordered to provide respondent with complainant’s letter and filed his comment within ten
days. However, respondent assumed that he did not receive a copy. He indicated his wonder as to why
his application for exemption could not be granted. He detailed his achievements as a lawyer, books he
authored and claimed that he had been practicing law for about fifty years.

The Court referred the respondent’s compliance and comment to the OBC for recommendation. The
OBC reported that the respondent applied for exemption for the First and Second Compliance Periods on
the ground of expertise in law. The MCLE Governing Board denied the request on January 14, 2009. The
OBC recommended that Adaza be affirmed a delinquent member of the Bar, guilty of non-compliance
with the MCLE requirements, and be suspended from the practice of law for six months.

ISSUE:
Whether or not the respondent is administratively liable for his failure to comply with the MCLE
requirements.

RULING:
Yes. The respondent is administratively liable for his failure to comply with the MCLE requirements as
supported by the records of MCLE office showing that the respondent failed to comply with the four
compliance periods. His application for exemption for the First and Second Compliance Periods was filed
after the compliance periods had ended. He did not follow-up the status of his application for
exemption. He claimed that his secretary failed to send his application for exemption to the MCLE office.
Moreover, he did not comply with the Fourth Compliance Period. The MCLE Governing Board also
denied his application for exemption due to him being unable to meet the requirements of expertise in
law. The court therefore declared Atty. Homobono Adaza a delinquent member of the Integrated Bar of
the Philippines and suspend him from the practice of law for six months, or until he has fully complied
with the MCLE requirements for the First, Second, Third, and Fourth Compliance Periods.