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Ernest Levanza Regalla vs Sandiganbayan Facts: 1.

Raul Roco and his colleagues from the ACCRA Law Office were charged together with Eduardo Conjuanco for acquiring ill-gotten wealth. 2. The PCGG based its charge from the refusal of the law firm to divulge information as to who had been involved in PCGG Case despite the nature of the services performed by ACCRA. a. Law firm knows the assets, personal transactions and business dealings of their clients 3. Later, the PCGG amended the complaint, resulting in the exclusion of ROCO from the list of defendants. Such exclusion was based from the manifestation of Roco that he would identify the persons and stockholders involved in the said PCGG case. 4. The law firm petitioned for the PCGG to grant them the same treatment as what had been accorded to Roco. 5. It was only at this point that the PCGG answered with a set of requirements and conditions for exclusion which were: a. Disclosure of the identity of the clients b. Submission of documents purporting to the substantiation of the lawyer-client relationship c. Presentation of the deeds of assignment which the lawyers executed in favor of its clients, covering the shareholdings of the latter. 6. To bolster this set up, the PCGG presented supposed proof to the effect that Roco had complied with such conditions. 7. Sandigan denied the petition of ACCRA Issue: Whether the Sandiganbayan erred in not giving the law firm equal treatment as that of Roco despite the fact that the confession of Roco did not really reveal the information being asked by the PCGG Whether the Sandiganbayan strictly applied the concept of agency Whether the Sandiganbayan did not uphold the sanctity of the lawyer-client relationship Held: Yes No Yes Ratio: 1. The inclusion of the ACCRA lawyers was merely being used as a leverage to compel them to name their clients, classifying persons as to those who can give valuable information apart from those who cannot is not a valid classification espoused by the equal protection clause 2. An attorney is more than a mere agent or servant because he possess special powers of trust and confidence reposed on him by his client 3. General rule: The identity of the client should not be shrouded with mystery, as a requirement of due process, except: a. Revealing the name of a client would implicate the latter in the very activity for which he sought the advice of the lawyer

b. The disclosure would expose the client to civil liability c. The content of the client communication is relevant to the subject matter of the legal problem on which the client seeks legal assistance i. The case of the prosecution must be built upon evidence gathered by them from their own sources, not from compelled testimony requiring them to reveal information prejudicial to their client ii. The confidentiality privilege extends even after the termination of the lawyer client relationship.