There are exceptions to rule that ‘clients are bound by mistakes of their lawyers’ -- SC


While clients are generally bound by the mistakes of their lawyers, there are exceptions like when a lawyer’s negligence violates due process or leads to the loss of a client’s liberty or property.

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“Indeed, if the strict application of the rules would tend to frustrate rather than promote justice, the Court is not without power to exercise its judicial discretion in relaxing the rules of procedure and prevent a miscarriage of justice,” the Supreme Court (SC) declared in a decision.

With its ruling, the SC – in a decision written by Associate Justice Samuel H. Gaerlan -- granted the petition of several laborers and ordered the Court of Appeals (CA) to allow them to file their appeal and resolve their case.

A summary of the decision issued by the SC’s Office of the Spokesperson stated that the laborers filed a case for illegal dismissal against their employer. 

The names of the parties were redacted in the summary of the case that was docketed as G.R. No. 267580.

The summary also stated: 

“After both the labor arbiter and the National Labor Relations Commissions (NLRC) dismissed their complaint, they brought their case to the CA where they had 60 days, or until Dec. 10, 2022, to file a petition for certiorari. 

“However, their lawyer failed to prepare the petition despite prior arrangements and payment. 

“Left without legal representation, they requested a 30- day extension, or until January 10, 2023, to find a new lawyer and file their case. 

“The CA rejected their request, indicating that they had not made sufficient efforts to hire a new lawyer. Consequently, it dismissed their petition, which they filed through new legal counsel on Jan. 10, 2023. 

“The laborers appealed to the SC, which ruled in their favor. 

“The SC clarified that while the 60-day deadline for filing a petition for certiorari is generally required, courts may grant extensions for valid reasons. 

“In this case, the laborers – who were minimum-wage workers with limited access to legal resources – were left stranded when their lawyers abandoned them. 

“Given their circumstances, the SC recognized that they could not be expected to immediately find new legal representation.  

“As a result, the SC ruled that the CA must hear their case, affirming the principle that the law should protect the most vulnerable: 

“Indubitably, the adage that ‘those who have less in life should have more in law’ is not an empty platitude, especially when there is a grave possibility that the less privileged, having relied in good faith on the assurances of a lawyer, were abruptly abandoned and were deprived their right to due process. 

“The Court rectifies this in the exercise of its primary duty, to render justice free from the constraints of technicalities. 

“Verily, our courts and tribunals should strike a balance between public policy and necessity – that of putting an end to litigation speedily, and yet harmonizing such necessity with the right of a litigant to an opportunity to be heard.” 

“The SC reinstated the case and directed the CA to resolve it based on its merits. 

“It also instructed the Commission on Bar Discipline of the Integrated Bar of the Philippines to investigate the lawyer’s conduct for potential administrative liability as a member of the Bar.”

Also, in 2023 the SC granted the petition of an accused for a review of his conviction by the trial court after his lawyer failed to file his appeal before the CA.

In that SC decision, also written by Associate Justice Gaerlan, the High Court recalled the entry of judgment issued by the CA and directed the appellate court to resolve the appeal of the accused who was sentenced to life imprisonment in 2012 and fined P500,000 on an illegal drugs case..

To deprive an accused, who relied in good faith on his or her counsel, the right to appeal is a violation of the right to due process, the SC pointed out.