[ A.C. No. 6837 (Formerly CBD Case No. 04-1287). October 28, 2025 ]

[ A.C. No. 6837 (Formerly CBD Case No. 04-1287). October 28, 2025 ]

EN BANC

[ A.C. No. 6837 (Formerly CBD Case No. 04-1287). October 28, 2025 ]

LARCY VALERIO, COMPLAINANT, VS. ATTY. ELERIZZA METEORO-LIBIRAN, RESPONDENT.

D E C I S I O N

LEONEN, SAJ.:

This Court may no longer disbar a lawyer who has been previously disbarred, but it may still impose administrative sanctions on them for violations of the Code of Professional Responsibility and Accountability committed prior to their disbarment.[1]

Through an October 10, 2024 Letter, Atty. Avelino V. Sales, Jr. as Director for Bar Discipline of the Integrated Bar of the Philippines' Commission on Bar Discipline, transmitted the documents pertaining to this case.[2] The following were submitted: (a) the Report and Recommendation of the Commission on Bar Discipline's Investigating Commissioner Emma O. Ferenal dated October 18, 2023, which recommended that Atty. Elerizza Meteoro-Libiran (Atty. Meteoro-Libiran) be disbarred for violating the Code of Professional Responsibility and Accountability;[3] and the Notice of Resolution No. XXVI-CRM-2024-06-26 dated June 27, 2024 issued by the Board of Governors of the Integrated Bar of the Philippines noting Atty. Meteoro-Libiran's prior disbarment, modifying the Report and Recommendation of the investigating commissioner, and recommending instead to impose upon Atty. Meteoro-Libiran a fine of PHP 101,000.00.[4]

The records show that Larcy Valerio (Valerio) filed an administrative complaint against one "Atty. Eleriza Meteoro-Libiran" because the post-dated checks that the latter issued as security for her loan were all dishonored when Valerio presented them for payment.[5]

Atty. Meteoro-Libiran ignored Valerio's formal demand for payment of the loan, as well as the subsequent criminal action that Valerio instituted against her for violation of Batas Pambansa Blg. 22.[6] This resulted in the Regional Trial Court issuing a warrant for her arrest.[7]

Atty. Meteoro-Libiran exhibited the same disregard for the concurrent disbarment proceedings initiated by Valerio. All attempts to notify Atty. Meteoro-Libiran of the disbarment complaint were returned unserved, which eventually led to her forfeiture of the opportunity to submit her position paper.[8] Thus, the Commission on Bar Discipline's investigating commissioner recommended her disbarment: WHEREFORE, premises considered, after considering the aggravating circumstances in the instant case, the undersigned investigating commissioner respectfully recommends that the respondent be meted with the penalty of DIBARMENT for violating the Code of Professional Responsibility and Accountability.[9] However, the Integrated Bar of the Philippines' Board of Governors Resolution No. XXVI-CRM-2024-06-26 dated June 27, 2024 modified the investigating commissioner's recommendation, noting that Atty. Meteoro-Libiran has already been previously disbarred:

RESOLUTION NO. XXVI-CRM-2024-06-26

RESOLVED, to MODIFY, as it is hereby MODIFIED, the Report and Recommendation of the Investigating Commissioner, noting that the respondent Atty. Eleriza Meteoro-Libiran is currently disbarred, and to recommend instead, to mete out upon her the penalty of FINE of ONE HUNDRED ONE THOUSAND PESOS ([PHP] 101,000.00), with STERN WARNING that a repetition of the same or similar act shall be dealt with more severely.[10] In view of these proceedings, this Court resolves the following issues:

First, whether respondent Atty. Elerizza Meteoro-Libiran is the same person as "Atty. Elerizza A. Libiran-Meteoro," who was administratively sanctioned in the prior cases of Barrientos v. Atty. Libiran-Meteoro[11] and Uy v. Atty. Libiran-Meteoro;[12] and

Second, whether respondent Atty. Meteoro-Libiran may be administratively sanctioned for violating the Code of Professional Responsibility and Accountability.

We rule affirmatively in both respects.

I

This Court is convinced that "Atty. Elerizza Meteoro-Libiran" and "Atty. Elerizza A. Libiran-Meteoro" are the same person.

When complainant Valerio's administrative complaint was first filed on August 9, 2004, proceedings stalled because respondent, named in the complaint as "Atty. Eleriza Meteoro-Libiran," could not be served with notice.[13] Later, on December 21, 2005, the Office of the Bar Confidant issued a Report and Recommendation stating that "Atty. Eleriza Meteoro-Libiran" was not listed in the Roll of Attorneys, and that only "Atty. Elerizza A. Libiran-Meteoro" was on record as having been meted a prior six-month suspension for issuing bouncing checks. The administrative case suspending her was docketed as A.C. No. 6408, entitled Barrientos v. Atty. Libiran-Meteoro.[14]

Upon the referral of the present case to this Court, we directed complainant to amend her complaint and to reflect respondent's "correct and complete name" ("Atty. Elerizza A. Libiran-Meteoro") and her proper address.[15] Complainant submitted the necessary amendments and the case to hold respondent administratively liable for violation of the Code of Professional Responsibility and Accountability proceeded.[16] However, respondent remained unreachable by notice. Throughout the proceedings, she failed to heed the demands for payment and notices to attend the legal proceedings instituted against her.[17]

We note that the behavior of respondent in Uy v. Atty. Libiran-Meteoro, "Atty. Elerizza A. Libiran-Meteoro," is identical to the behavior exhibited by respondent in the present case: The fact that Atty. Libiran-Meteoro issued the subject checks, which were later dishonored for the reason "ACCOUNT CLOSED" and "DAIF" or drawn against insufficient funds, is duly evidenced by copies of the dishonored checks submitted by Uy. There is thus no question that he was able to hurdle the quantum of evidence required in disbarment proceedings, i.e., substantial evidence or "that amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion."

Meanwhile, considering the totality of the facts on record, the Court ordains that Atty. Libiran-Meteoro's issuance of the unfunded checks was willful and intentional. First, she blatantly ignored Uy's calls to pay the amounts covered by the subject checks; and second, her present and past infractions reflected her modus of issuing worthless checks to obtain loans from unknowing victims.[18] (Emphasis supplied, citations omitted) Thus, Uy disbarred "Atty. Elerizza A. Libiran-Meteoro." Uy also referenced the earlier case of Barrientos, which suspended "Atty. Elerizza A. Libiran-Meteoro" from legal practice because of the same fraudulent scheme: In Barrientos v. Atty. Libiran-Meteoro, Atty. Libiran-Meteoro was previously found guilty of gross misconduct when she issued two worthless Equitable PCI Bank checks in the amounts of PHP 67,000.00 and PHP 234,000.00, respectively, in favor of the complainants therein for payment of a pre-existing debt. The checks bounced due to insufficient funds. Atty. Libiran-Meteoro later on committed to pay her debt to the complainants but failed many times to fulfill her promises. When finally threatened with criminal charges for violation of Batas Pambansa Blg. 22, she gave the complainants a title of a parcel of land she claimed was paid to her by a client, Victoria Villamar (Villamar), but which turned out to have merely been entrusted to her pursuant to a transaction with the Quedan and Rural Credit Guarantee Corporation. Though the Court did not find Atty. Libiran-Meteoro liable for negotiating a title entrusted to her by Villamar for insufficiency of evidence, she was suspended for six months from the practice of law as a penalty for issuing worthless checks, taking into consideration her partial payment of PHP 50,000.00.

Considering her previous offense, the Court finds that the imposition of the supreme penalty of disbarment upon Atty. Libiran-Meteoro is warranted. In her first case, Atty. Libiran-Meteoro already displayed quite flagrantly her propensity to defraud people by employing unlawful means to secure loans. Instead of owning up to her obligations, she repeatedly failed to make good her promises to pay such that therein complainants were ultimately compelled to file suits against her. Undaunted, she again repeated her infractions here. She defrauded Uy, and issued anew two checks in the amounts of PHP 122,500.00 each or PHP 245,000.00 in total which apparently were unfunded. As in the first case, she brazenly failed to pay her debt despite numerous demands. She could not be contacted. She ignored calls.[19] (Emphasis supplied, citations omitted) The foregoing circumstances led the Commission on Bar Discipline's investigating commissioner and the Board of Governors to conclude that herein respondent Atty. Meteoro-Libiran employed the same scheme of using a false name to mislead and deceive others, ignore notices from courts and administrative bodies, and evade responsibility for her actions: The propensity of the respondent to issue worthless checks, her deliberate failure if not refusal to pay the same, her glaring display of arrogance by her willful act of ignoring the demands made by the complainant, her use of different name (sic) in order to conceal her identity and her wanton disregard of the orders of the [Integrated Bar of the Philippines] in filing her answer and position paper are tainted with bad faith and malice which call for an administrative sanction.[20] The minor difference in the names used by respondent in the present case and in the cases of Uy and Barrientos cannot overcome the exactness by which she reproduced the same scheme employed in the aforementioned cases. "Atty. Elerizza Meteoro-Libiran" and "Atty. Elerizza A. Libiran-Meteoro" are the same person. Ruling otherwise would only accommodate respondent's repeated deceptions and disregard of her professional responsibilities.

II

Respondent must be held liable for yet another violation of the Code of Professional Responsibility and Accountability. Her issuance of bouncing checks to secure her unpaid loan obligation to complainant violates Canon II, Sections 1 and 2 of the Code of Professional Responsibility and Accountability. As aptly discussed in Uy: The act of Atty. Libiran-Meteoro in issuing worthless checks and blatantly ignoring demands to pay is, without a doubt, unlawful, dishonest, and deceitful. To be sure, it violates Batas Pambansa Blg. 22, which penalizes the making or drawing and issuance of worthless checks which results in injury to the public. The harmful practice of putting valueless commercial papers in circulation, multiplied a thousandfold, can pollute the channels of trade and commerce, injure the banking system and eventually hurt the welfare of society and the public interest.

As a member of the Bar, Atty. Libiran-Meteoro was expected, not only to know the deleterious and pernicious effect of issuing worthless checks and the fact that it is proscribed by law but be the first to faithfully abide by its provisions. Yet, this did not deter her from committing this unlawful act. Our ruling in Ong v. Atty. Delos Santos, where We found Atty. Delos Santos administratively liable for issuing bouncing checks, is apropos: Being a lawyer, Atty. Delos Santos was well aware of the objectives and coverage of Batas Pambansa Blg. 22. If he did not, he was nonetheless presumed to know them, for the law was penal in character and application. His issuance of the unfunded check involved herein knowingly violated Batas Pambansa Blg. 22, and exhibited his indifference towards the pernicious effect of his illegal act to public interest and public order. He thereby swept aside his Lawyer's Oath that enjoined him to support the Constitution and obey the laws. Apart from being unlawful, Atty. Libiran-Meteoro's issuance of the subject checks constituted dishonest and deceitful conduct. To recall, the reason why Uy agreed to loan her money was because she assured him that the post-dated checks she issued as payment would be good when they fall due. As it turned out, however, the checks were not sufficiently funded or were drawn against a closed account and consequently got dishonored, revealing Atty. Libiran-Meteoro's ruse, to the damage and prejudice of Uy. Worse, the dishonesty she exhibited was exacerbated by her continued refusal to pay, much less acknowledge, her obligation.

To the mind of the Court, there is no question that Atty. Libiran-Meteoro fell short of the high standards of morality and integrity expected of members of the Bar. Her brazen deception and utter disregard of her financial obligations cast a dishonorable light on the supposedly dignified and noble profession she represents, for which she must be held accountable.

In Carrillo v. Atty. Soriano, We found Atty. Soriano guilty of serious misconduct for issuing worthless checks, in violation of Batas Pambansa Blg. 22. "Serious or gross misconduct" has been defined as improper or wrong conduct, the transgression of some established and definite rule of action, a forbidden act, a dereliction of duty, willful in character, and implies a wrongful intent and not a mere error in judgment.

. . . .

Unquestionably, Atty. Libiran-Meteoro is guilty of gross misconduct. Canon VI, Section 33 of the [Code of Professional Responsibility and Accountability] classifies gross misconduct as a serious offense for which the following penalties may be imposed: (1) disbarment; (2) suspension from the practice of law for a period exceeding six months; (3) revocation of notarial commission and disqualification as notary public for not less than two years; or (4) a fine exceeding PHP 100,000.00.

Per Canon VI, Section 39 of the [Code of Professional Responsibility and Accountability], if one or more aggravating circumstances and no mitigating circumstances are present, the Court, in its discretion, may impose the penalty of disbarment depending on the number and gravity of aggravating circumstances. Under Section 38(b)(l) of the same Canon, a finding of previous administrative liability where a penalty is imposed, regardless of nature or gravity, counts as an aggravating circumstance.[21] (Emphasis supplied, citations omitted) However, in view of respondent's prior disbarment in Uy, this Court may no longer disbar her a second time. Rather, the case of Felix v. Gadon[22] provides that repeated violations may be noted on the disbarred lawyer's personal file and may be cause for the imposition of a fine or other administrative sanctions deemed necessary by the Court, pursuant to Canon VI, Section 42 of the Code of Professional Responsibility and Accountability: The Court now proceeds to discuss the penalty to be imposed. As Atty. Gadon was previously meted the ultimate penalty of disbarment in the previous case of In Re: Atty. Lorenzo G. Gadon's Viral Video Against Ms. Raissa Robles, the penalty of disbarment cannot be imposed. However, Section 42, Canon VI of the [Code of Professional Responsibility and Accountability] now finds application in the instant case: SECTION 42. Penalty When the Respondent Has been Previously Disbarred. — When the respondent has been previously disbarred and is subsequently found guilty of a new charge, the Court may impose a fine or order the disbarred lawyer to return the money or property to the client, when proper. If the new charge deserves the penalty of a disbarment or suspension from the practice of law, it shall not be imposed but the penalty shall be recorded in the personal file of the disbarred lawyer in the Office of the Bar Confidant or other office designated for the purpose. In the event that the disbarred lawyer applies for judicial clemency, the penalty so recorded shall be considered in the resolution of the same. Consistent with the [Code of Professional Responsibility and Accountability], the Court directs the Office of the Bar Confidant to record the infraction of Atty. Gadon in his personal file.

Considering that Atty. Gadon had already been meted the ultimate penalty of disbarment, aside from recording the infraction in his personal file, a fine of PHP150,000.00 is imposed on Atty. Gadon, pursuant to the Court's power to regulate the conduct of lawyers prior to their disbarment. The pronouncement of the Court in Valmonte v. Atty. Quesada is clear: But while the Court can no longer impose the penalty upon the disbarred lawyer, it can still give the corresponding penalty only for the sole purpose of recording it in his personal file with the Office of the Bar Confidant (OBC), which should be taken into consideration in the event that the disbarred lawyer subsequently files a petition to lift his disbarment.

In addition, the Court may also impose a fine upon a disbarred lawyer found to have committed an offense prior to his/her disbarment as the Court does not lose its exclusive jurisdiction over other offenses committed by a disbarred lawyer while he/she was still a member of the Law Profession. In fact, by imposing a fine, the Court is able "to assert its authority and competence to discipline all acts and actuations committed by the members of the Legal Profession." We reiterate that prior to his disbarment in A.C. No. 13521, Atty. Gadon has been the subject of previous administrative complaints, where he was found guilty and appropriately punished. Atty. Gadon was also warned that repetition of those acts or similar acts will warrant the imposition of a higher penalty. Unfortunately, Atty. Gadon refused to heed the warnings of the Court.[23] (Emphasis supplied, citations omitted) Thus, the Integrated Bar of the Philippines' Board of Governors Resolution No. XXVI-CRM-2024-06-26 dated June 27, 2024 must be modified to indicate the recording of respondent's violation in her personal file with the Office of the Bar Confidant. Further, the dispositive portion must indicate that such records may be considered in case she seeks reinstatement into the legal profession through judicial clemency. We find no reason to modify respondent's fine, as Canon VI, Section 37(a)(4) of the Code of Professional Responsibility and Accountability allows the imposition of a "fine exceeding [PHP] 100,000.00" for serious offenses.[24]

ACCORDINGLY, the Court finds respondent Atty. Elerizza Meteoro-Libiran a.k.a. "Atty. Elerizza A. Libiran-Meteoro" GUILTY of violating Canon II, Sections 1 and 2 of the Code of Professional Responsibility and Accountability and imposes upon her the penalty of DISBARMENT from the practice of law.

However, in view of her earlier disbarment in Uy v. Atty. Libiran-Meteoro,[25] disbarment may no longer be imposed, but must nonetheless be recorded in respondent's personal file pursuant to Canon VI, Section 42 of the Code of Professional Responsibility and Accountability. This record should be considered in the event that respondent applies for judicial clemency.

Accordingly, in view of her prior disbarment, respondent is hereby FINED in the amount of PHP 101,000.00, consistent with Canon VI, Section 37(a)(4) of the Code of Professional Responsibility and Accountability.

Let a copy of this Decision be furnished the Office of the Bar Confidant to be appended to the personal record of Atty. Elerizza Meteoro-Libiran a.k.a. "Atty. Elerizza A. Libiran-Meteoro" as an attorney; the Integrated Bar of the Philippines for its information and guidance; and the Office of the Court Administrator for circulation to all the courts.

This Decision is immediately executory.

SO ORDERED.

Gesmundo, C.J., Caguioa, Hernando, Lazaro-Javier, Inting, Gaerlan, Dimaampao, Marquez, and Singh, JJ., concur. Zalameda,* Rosario,* Lopez,* and Kho, Jr.,* JJ., on official business. Villanueva,** J., on official leave.

* On official business.

** On official leave.

[1] Felix v. Gadon, 951 Phil. 620, 635 (2024) [Per Curiam, En Banc].

[2] Rollo, p. 46.

[3] Id. at 49-58.

[4] Id. at 47-48.

[5] Id. at 52.

[6] Id.

[7] Id. at 52-53.

[8] Id. at 49-51.

[9] Id. at 58.

[10] Id. at 47.

[11] 480 Phil. 661 (2004) [Per J. Austria-Martinez, Second Division].

[12] 954 Phil. 387 (2024) [Per Curiam, En Banc].

[13] Rollo, pp. 49-50.

[14] Id. at 50. See also 480 Phil. 661 (2004) [Per J. Austria-Martinez, Second Division].

[15] Id.

[16] Id. at 50-51.

[17] Id. at 51-52.

[18] Uy v. Atty. Libiran-Meteoro, 954 Phil. 387, 393-394 (2024) [Per Curiam, En Banc].

[19] Id. at 395.

[20] Rollo, pp. 57-58.

[21] Uy v. Atty. Libiran-Meteoro, 954 Phil. 387, 392-394 (2024) [Per Curiam, En Banc].

[22] 951 Phil. 620 (2024) [Per Curiam, En Banc].

[23] Id. at 635-636.

[24] SC Administrative Matter No. 22-09-01-SC, Code of Professional Responsibility and Accountability, Canon VI, sec. 37(a)(4).

[25] 954 Phil. 387 (2024) [Per Curiam, En Banc].