PALE Cases Under Atty Rivero

DANTE LA JIMENEZ & LAURO G. VIZCONDE, vs. ATTY. FELISBERTO L.
VERANO, JR.
(AC 8108. July, 2014)
FACTS: The complainants in Administrative Case (A.C.) No. 8108 are Dante La
Jimenez and Lauro G. Vizconde, while complainant in Adm. Case No. 10299 is Atty.
Oliver O. Lozano.
At the time of the filing of the complaints, respondent Atty. Verano was representing his
clients Richard S. Brodett and Joseph R. Tecson. Brodett and Tecson (identified in
media reports attached to the Complaint as the “Alabang Boys”) were the accused in
cases filed by PDEA for the illegal sale and use of dangerous drugs.
In a Joint Inquest Resolution, the charges were dropped for lack of probable cause.
Because of the failure of Prosecutor John R. Resado to ask clarificatory questions
during the evaluation of the case, several media outlets reported on incidents of bribery
and “cover-up” allegedly prevalent in investigations of the drug trade. This prompted the
House Committee on Illegal Drugs to conduct its own congressional hearings.
It was revealed during one such hearing that respondent had prepared the release
order for his three clients using the letterhead of the Department of Justice (DOJ) and
the stationery of then Secretary Raul Gonzales. Jimenez and Vizconde, in their capacity
as founders of Volunteers Against Crime and Corruption (VACC), sent a letter of
complaint to Chief Justice Reynato S. Puno. They stated that respondent had admitted
to drafting the release order, and had thereby committed a highly irregular and unethical
act. He had no authority to use the DOJ letterhead and should be penalized for acts
unbecoming a member of the bar.
For his part, Atty. Lozano anchored his Complaint on respondent’s alleged violation of
Canon 1 of the Code of Professional Responsibility, which states that a lawyer shall
uphold the Constitution, obey the laws of the land, and promote respect for legal
processes. Atty. Lozano contended that respondent showed disrespect for the law and
legal processes in drafting the said order and sending it to a high-ranking public official,
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even though the latter was not a government prosecutor. Atty. Lozano withdrew his
Complaint on the ground that a similar action had been filed by Dante Jimenez.
DEFENSE: Sheer faith in the innocence of his clients and fidelity to their cause
prompted him to prepare and draft the release order. Respondent admits that perhaps
he was overzealous; yet, âif the Secretary of Justice approves it, then everything may
be expedited. In any case, respondent continues, the drafted release order was not
signed by the Secretary and therefore remained “a mere scrap of paper with no effect at
all.” The Investigating Commissioner noted that both complaints remained
unsubstantiated, while the letter-complaint of Jimenez and Vizconde had not been
verified. Therefore, no evidence was adduced to prove the charges. However, by his
own admissions in paragraphs 11 and 12 of his Comment, respondent drafted the
release order specifically for the signature of the DOJ Secretary. This act of “feeding”
the draft order to the latter was found to be highly irregular, as it tended to influence a
public official. Hence, Commissioner Abelita found respondent guilty of violating Canon
13 of the Code of Professional Responsibility and recommended that he be issued a
warning not to repeat the same or any similar action.
ISSUE: Whether or not Verano should be suspended for violating CPR.
HELD: Atty. Felisberto L. Verano, Jr. is found guilty of violating Rules 1.02 and 15.07, in
relation to Canon 13 of the Code of Professional Responsibility, for which he
is SUSPENDED from the practice of law for six (6) months. The Court may conduct its
own investigation into charges against members of the bar, irrespective of the form of
initiatory complaints brought before it. Thus, a complainant in a disbarment case is not a
direct party to the case, but a witness who brought the matter to the attention of the
Court.
By now, it is basic that there is neither a plaintiff nor a prosecutor in disciplinary

proceedings against lawyers. The real question for determination in these proceedings
is whether or not the attorney is still a fit person to be allowed the privileges of a
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member of the bar. The affidavit of withdrawal of the disbarment case allegedly
executed by complainant does not, in any way, exonerate the respondent. A case of
suspension or disbarment may proceed regardless of interest or lack of interest of the
complainant. What matters is whether, on the basis of the facts borne out by the record,
the charge of deceit and grossly immoral conduct has been duly proven xxx. The
complainant or the person who called the attention of the court to the attorney’s alleged
misconduct is in no sense a party, and has generally no interest in the outcome except
as all good citizens may have in the proper administration of justice.
Hence, if the evidence on record warrants, the respondent may be suspended or

disbarred despite the desistance of complainant or his withdrawal of the charges.
Canon 13 states that a lawyer shall rely upon the merits of his cause and refrain
from any impropriety which tends to influence, or gives the appearance of
influencing the court.
We believe that other provisions in the Code of Professional Responsibility likewise

prohibit acts of influence-peddling not limited to the regular courts, but even in all other
venues in the justice sector, where respect for the rule of law is at all times demanded
from a member of the bar. During the mandatory hearing, the following statements were
established as respondent’s admission that:
1) he personally approached the DOJ Secretary despite the fact that the case was still
pending before the latter; and
2) respondent caused the preparation of the draft release order on official DOJ
stationery despite being unauthorized to do so, with the end in view of expediting the
case.
The way respondent conducted himself manifested a clear intent to gain special
treatment and consideration from a government agency. This is precisely the type of
improper behavior sought to be regulated by the codified norms for the bar. The primary
duty of lawyers is not to their clients but to the administration of justice. To that end,
their clients’ success is wholly subordinate. The conduct of a member of the bar ought
to and must always be scrupulously observant of the law and ethics. Any means, not
honorable, fair and honest which is resorted to by the lawyer, even in the pursuit of his
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devotion to his client’s cause, is condemnable and unethical. Zeal and persistence in
advancing a clientâs cause must always be within the bounds of the law.
Rule 1.02 states: A lawyer shall not counsel or abet activities aimed at defiance of
the law or at lessening confidence in the legal system. Further, according to Rule
15.06, a lawyer shall not state or imply that he is able to influence any public
official, tribunal or legislative body. The succeeding rule, Rule 15.07, mandates a
lawyer to impress upon his client compliance with the laws and the principles of
fairness.
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FOSTER vs AGTANG A.C. No. 10579 – Legal Ethics – Borrowing From Clients Not Appropriate
Civil Claims Cannot Be Litigated in a Disbarment Suit
FACTS: In 2009, Erlinda Foster engaged the services of Atty. Jaime Agtang in a realty dispute in
Ilocos Norte. Agtang’s acceptance fee was P20,000.00 plus P5,000.00 for incidental expenses.
For the case, Agtang collected P150,000.00 from Foster as filing fee. He also advised Foster to
shell out a total of P50,000.00 for them to bribe the judge and get a favorable decision.
Although reluctant, Foster gave in to Agtang’s demands.
On various occasions, Agtang borrowed money from Foster for his personal use, i.e., car repair.
Such loan amounted to P122,000.00. Foster, being prudent, asked for receipts for all funds she
handed over to Agtang.
Later however, Foster learned that she lost the case due to Agtang’s negligence and
incompetence in drafting the complaint. She also found out that the filing fee therefor was only
P22,410 (not P150k). Further, it turned out that Agtang was once the lawyer of the opposing
party. When she asked Agtang to return her the balance, the said lawyer failed to do so hence,
she filed an administrative complaint against Agtang.
The IBP Board of Governors (IBP-BOG) eventually ordered Agtang to return the balance of the
filing fee (P127,590.00) as well as the money he borrowed from Foster (P122,000.00). It was
also recommended that Agtang be suspended for three months only.
ISSUE: Whether or not the recommendation by the IBP-BOG is proper.
HELD: No. The recommended penalty of 3 months suspension is too light. Agtang
was disbarred by the Supreme Court.
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Rule 1.0, Canon 1 of the Code of Professional Responsibility, provides that “a lawyer shall not
engage in unlawful, dishonest, immoral or deceitful conduct.”
In this case, Agtang is guilty of engaging in dishonest and deceitful conduct, both in his
professional and private capacity. As a lawyer, he clearly misled Foster into believing that the
filing fees for her case were worth more than the prescribed amount in the rules, due to
feigned reasons such as the high value of the land involved and the extra expenses to be
incurred by court employees. In other words, he resorted to overpricing, an act customarily
related to depravity and dishonesty.
When asked to return the balance, he failed and refused to do so and even had the temerity
that it was all the client’s idea. . A lawyer’s failure to return upon demand the funds held by him
on behalf of his client gives rise to the presumption that he has appropriated the same for his
own use in violation of the trust reposed in him by his client. Such act is a gross violation of
general morality as well as of professional ethics. It impairs public confidence in the legal
profession and deserves punishment.
It is clear that Agtang failed to fulfill this duty. He received various amounts from Foster but he
could not account for all of them. Worse, he could not deny the authenticity of the receipts
presented by Foster.
Rule 16.04, Canon 16 of the Code of Professional Responsibility states that “a lawyer shall not
borrow money from his client unless the client’s interests are fully protected by the nature of
the case or by independent advice. Neither shall a lawyer lend money to a client except, when
in the interest of justice, he has to advance necessary expenses in a legal matter he is handling
for the client.”
In the first place, Agtang should have never borrowed from Foster, his client. Second, his refusal
to pay reflects his baseness. Deliberate failure to pay just debts constitutes gross misconduct,
for which a lawyer may be sanctioned with suspension from the practice of law. Lawyers are
instruments for the administration of justice and vanguards of our legal system. They are
expected to maintain not only legal proficiency, but also a high standard of morality, honesty,
integrity and fair dealing so that the people’s faith and confidence in the judicial system is
ensured. They must, at all times, faithfully perform their duties to society, to the bar, the courts
and their clients, which include prompt payment of financial obligations.
The acts of the Agtang constitute malpractice and gross misconduct in his office as attorney. His
incompetence and appalling indifference to his duty to his client, the courts and society render
him unfit to continue discharging the trust reposed in him as a member of the Bar.
SIDE ISSUE: May the Court order Agtang to return the money he borrowed from Foster?
No. The Court held that it cannot order the lawyer to return money to complainant if he or she
acted in a private capacity because its findings in administrative cases have no bearing on
liabilities which have no intrinsic link to the lawyer’s professional engagement. In disciplinary
proceedings against lawyers, the only issue is whether the officer of the court is still fit to be
allowed to continue as a member of the Bar. The only concern of the Court is the determination
of respondent’s administrative liability. Its findings have no material bearing on other judicial
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actions which the parties may choose against each other. To rule otherwise would in effect
deprive respondent of his right to appeal since administrative cases are filed directly with the
Court.
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A.C. No. 10573, January 13, 2015

FERNANDO W. CHU, Complainant, v. ATTY. JOSE C. GUICO, JR., Respondents.
FACTS: Chu retained Atty. Guico as counsel to handle the labor disputes involving
his company, CVC San Lorenzo Ruiz Corporation (CVC). For several instances, Atty.
Guico asked Chu to prepare a substantial amount of money to be given to the NLRC
Commissioner handling the case to insure a favorable decision. He was able to
collect a sum of Php 580,000.00 but when NLRC promulgated a decision, CVC lost
its case.
ISSUE: Whether or not Atty. Guico violated the lawyer's oath and Rule 1.01 of the
CPR for demanding and receiving Php580,000 from Chu to guarantee a favorable
decision from NLRC?
HELD: Yes. Atty. Guico's acts constituted gross dishonesty and deceit, and were a
flagrant breach of his ethical commitments under the Lawyer’s Oath not to delay any
man for money or malice; and under Rule 1.01 of the Code of Professional
Responsibility that forbade him from engaging in unlawful, dishonest, immoral or
deceitful conduct
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ANTONINA S. SOSA v. ATTY. MANUEL V. MENDOZA A.C. No. 8776.

March 22, 2015
FACTS: On July 28, 2006, Antonia Sosa extended a loan of PS00,000.00 to Atty.
Mendoza at an interest of P2S,000.00 to be paid not later than September 2S, 2006.
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They agreed that a penalty or collection charge of 10% per month shall accrue in case
of default. To ensure the payment of the obligation, Atty. Mendoza signed a promissory
note and issued a postdated check for PS00,000.00.
Atty. Mendoza failed to comply with his obligation on due date. Upon demand to pay,
he requested Ms. Sosa not to deposit the postdated check. She acceded and
deferred the deposit of the check based on Atty. Mendoza's promise that he would
later pay. The check was subsequently returned/dishonored after Ms. Sosa finally
deposited it sometime in October
2006; it was "Drawn Against Insufficient Funds."
PETITIONER'S CONTENTION:
Ms. Sosa, thru her lawyer Atty. Ernesto V. Cabrera, sent a letter to Atty. Mendoza
demanding payment of the loan plus interest and collection charges. Atty. Mendoza
ignored the demand letter despite receipt, as proven by the Registry Receipt and
Registry Return Receipt. Likewise, he did not, in any
manner, contact Ms. Sosa to explain why he failed to pay. In view of the repeated
failure of Atty. Mendoza to pay, Ms. Sosa filed the complaint for disbarment or
suspension, charging Atty. Mendoza for violation of Rule 1.01 of the Code of
Professional Responsibility. This Rule states that "[a] lawyer shall not engage in
unlawful, dishonest, immoral or deceitful conduct."
RESPONDENT'S CONTENTION:
Atty. Mendoza admitted the existence of the loan and that it is a valid obligation.
However, he alleged that he only received One Hundred
Thousand Pesos (P100,000.00) from one Elenita Cruz (Elenita), a friend of the
complainant. Atty. Mendoza did not attach an affidavit from Elenita nor any evidence
proving that he only received P100,000.00.
IBP FINDINGS & RECOMMENDATION:

The Investigating Commissioner found Atty. Mendoza liable not only administratively
but also civilly. The IBP Board of Governors adopted with modification the findings of
the Investigating Commissioner ruling that the respondent is guilty of misconduct for
his failure to pay a just and valid debt thus, Atty. Manuel V. Mendoza is hereby
SUSPENDED from the practice of law for 6 months and Ordered to Return the
amount of PS00,000.00 to the complainant with legal interest.
ISSUES:
1) WHETHER OR NOT ATTY. MENDOZA SHOULD BE HELD LIABLE?

2) WHETHER THE COMPLAINANT CAN COLLECT THE AMOUNT OF THE
OBLIGATION OF THE LOAN IN A DISBARMENT CASE?
HELD:
1) YES.
'Any gross misconduct of a lawyer in his professional or in his private capacity is a
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ground for the imposition of the penalty of suspension or disbarment
because good character is an essential qualification for the admission to and continued
practice of law. Any wrongdoing, whether professional or non- professional, indicating
unfitness for the profession justifies disciplinary action."
Gross misconduct is 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."
Rule 1.01 of the Code of Professional Responsibility is emphatic: 'Ta] lawyer

shall not engage in unlawful, dishonest, immoral or deceitful conduct."
The facts of the case show that Atty. Mendoza engaged in improper or wrong conduct
as the failure to pay the loan was willful in character and implied a wrongful intent and
not a mere error in judgment.
It is undisputed that Atty. Mendoza obtained a loan in the amount of PS00,000.00. He

signed the promissory note and acknowledgement receipt showing he received
PS00,000.00.19 Although he initially denied getting this amount and claimed that he
only received P100,000.00, he did not present any evidence to prove his claim. He
later also admitted the validity of his loan without qualification as to the amount. Also
undisputed is the fact that Ms. Sosa tried to collect the amount due upon maturity but
Atty. Mendoza failed to pay. In fact, Ms. Sosa deferred depositing the postdated check
upon Atty. Mendoza's request, and based on his promises that he would pay. Despite
all these, he still failed to comply with his obligation. Worse, the check - when finally
deposited - was dishonored, a fact that Atty. Mendoza did not dispute.
Atty. Mendoza further claimed he had P600,000.00 on hand during the hearing
with the IBP Investigating Officer. He allegedly failed to deliver the amount to Ms. Sosa
or her counsel because he arrived late. The Court found that Atty. Mendoza's excuse to
be flimsy. It could have been very easy for him to deliver the P600,000.00 to Ms. Sosa if
he had the real intention to pay. Atty. Mendoza was also not candid with the IBP
Investigating Officer when he
claimed he had P600,000.00 and that he was ready to pay his obligation. What is
clear is that his obligation remains outstanding after all these years.
Other than his claim that he was disposing of real properties in order to settle his
obligation, Atty. Mendoza also failed to explain why he failed to pay despite his
admission of a just and valid loan. Whatever his reasons or excuses may be, dire
financial condition does not justify non-payment of debt.
The facts and evidence in this case clearly establish Atty. Mendoza's failure to live up
to his duties as a lawyer as dictated by the lawyer's oath, the Code of Professional
Responsibility and the Canons of Professional Ethics, thereby degrading not only his
personal integrity but his profession as well. To reiterate, his failure to honor his
just debt constitutes dishonest and deceitful conduct. This dishonest conduct was
compounded by Atty. Mendoza's act of interjecting flimsy excuses that only
strengthened the conclusion that he refused to pay a valid and just debt
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2) No.
The SC differ with the IBP's recommendation ordering Atty. Mendoza to pay the
amount of the loan plus legal interest because the instant case is solely an
administrative complaint for disbarment and is not a civil action for collection of a sum
of money.
The quantum of evidence in these two types of cases alone prevents the court from
agreeing with the IBP's order to pay; the administrative complaint only requires
substantial evidence to justify a finding of liability, while a civil action requires greater
evidentiary standard of preponderance of evidence.
A proceeding for suspension or disbarment is not a civil action where the complainant
is a plaintiff and the respondent lawyer is a defendant. Disciplinary proceedings
involve no private interest and afford no redress for private grievance. They are
undertaken and prosecuted solely for the public welfare. In the recent case of Heenan
v. Atty. Espejo (A.C. No. 10050, December 3, 2013, 711 SCRA 290), The SC En
Banc did not agree with the
IBP's recommendation to order the erring lawyer to return the money he borrowed from
the complainant, to wit:
In disciplinary proceedings against lawyers, the only issue is whether the

officer of the court is still fit to be allowed to continue as a member of the Bar.
Our only concern is the determination of respondent's administrative liability.
Our findings have no material bearing on other judicial action which the parties
may choose to file against each other. Furthermore, disciplinary proceedings
against lawyers do not involve a trial of an action, but rather investigations by
the Court into the conduct of one of its officers. The only question for
determination in these proceedings is whether or not the attorney is still
fit to be allowed to continue as a member of the Bar. Thus, this Court
cannot rule on the issue of the amount of money that should be returned
to the complainant. [Emphasis supplied and citations omitted.]
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ACA v. SALVADO
A.C. No. 10952 | January 26, 2016
FACTS:
Engel Paul Aca filed an administrative complaint3 for disbarment against Atty. Salvado
for violation of Canon 1, Rule 1.014 and Canon 7, Rule 7.035 of the Code of Professional
Responsibility (CPR).
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Complainant alleged, among others, that sometime in 2010, he met Atty. Salvado through
Atty. Samuel Divina (Atty. Divina), his childhood friend; that Atty. Salvado introduced
himself as a lawyer and a businessman engaged in several businesses including but not limited to
the lending business; that on the same occasion, Atty. Salvado enticed the complainant to
invest in his business with a guarantee that he would be given a high interest rate of 5% to
6% every month; and that he was assured of a profitable investment due by Atty. Salvado
as the latter had various clients and investors.
As consideration for these investments, Atty. Salvado issued several post-dated checks in
the total amount of P6,107,000.00, representing the principal amount plus interests. All
checks were drawn from PSBank.
Upon presentment, however, complainant was shocked to learn that the aforementioned
checks were dishonored as these were drawn from insufficient funds or a closed account.
Complainant made several verbal and written demands upon Atty. Salvado. As time went
by, however, Atty. Salvado began to avoid complainant’s calls and text messages. This
prompted complainant to refer the matter to his lawyer Atty. Divina, for appropriate legal
action.
Atty. Divina personally served the Notice of Dishonor on Atty. Salvado, directing him to settle
his total obligation in the amount of P747,000.00. Atty. Salvado refused to receive the said
notice.
Complainant went to Atty. Salvado’s house to personally serve the demand letter. A certain
“Mark” who opened the gate told the filing clerk that Atty. Salvado was no longer residing there
and had been staying in the province already.
As they were about to leave, a red vehicle arrived bearing Atty. Salvado. Complainant quickly
alighted from his vehicle and confronted him as he was about to enter the gate of the house.
Obviously startled, Atty. Salvado told him that he had not forgotten his debt. During this
conversation, Atty. Salvado assured complainant that he was working on “something” to pay his
obligations. He still refused to personally receive or, at the least, read the demand letter.
Despite his promises, Atty. Salvado failed to settle his obligations
Atty. Salvado denied that he told complainant that he had previously entered into various
government contracts and that he was previously engaged in some other businesses prior to
engaging in the lending and rediscounting business. Atty. Salvado asserted that he never enticed
complainant to invest in his business, but it was Atty. Divina’s earnings of good interest that
attracted him into making an investment.
The checks he issued were merely intended as security or evidence of investment.
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Atty. Salvado also claimed that, in the past, there were instances when he would request
complainant not to deposit a check knowing that it was not backed up by sufficient funds. This
arrangement had worked until the dishonor of the checks, for which he readily offered his house
and lot located in Marikina City as collateral.
Investigating Commissioner recommended that Atty. Salvado be meted a penalty of suspension

from the practice of law for six (6) months.
IBP-BOG adopted and approved the recommendation with modification – increased the period
of suspension from six (6) months to two (2) years.
ISSUE:
WON ATTY. SALVADO should be suspended for he violated CPR and the Lawyer’s Oath
HELD:
YES.
RATIO:
1. The public is, indeed, inclined to rely on representations made by lawyers. As a man
of law, a lawyer is necessarily a leader of the community, looked up to as a model
citizen. A man, learned in the law like Atty. Salvado, is expected to make truthful
representations when dealing with persons, clients or otherwise. For the Court, and as the
IBP-BOG had observed, complainant’s being beguiled to part with his money and
believe Atty. .Salvado as a lawyer and businessman was typical human behavior worthy
of belief. The Court finds it hard to believe that a person like the complainant would not
find the profession of the person on whose businesses he would invest as important to
consider. Simply put, Atty. Salvado’s stature as a member of the Bar had, in one way
or another, influenced complainant’s decision to invest.
2. The excuse of “gullibility and inadvertence” deserves scant consideration. Surely, Atty.
Salvado is aware that promoting obedience to the Constitution and the laws of the land is
the primary obligation of lawyers. When he issued the worthless checks, he discredited
the legal profession and created the public impression that laws were mere tools of
convenience that could be used, bended and abused to satisfy personal whims and
desires. In Lao v. Medel, the Court wrote that the issuance of worthless checks
constituted gross misconduct, and put the erring lawyer’s moral character in serious
doubt, though it was not related to his professional duties as a member of the Bar.
Covered by this dictum is Atty. Salvado’s business relationship with complainant.
His issuance of the subject checks display his doubtful fitness as an officer of the
court. Clearly, he violated Rule 1.01 and Rule 7.03 of the CPR.
3. The Court cannot overlook Atty. Salvado’s deceiving attempts to evade payment of
his obligations.
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DISPOSITION: SUSPENDED from the practice of law for a period of two (2) years.
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A.C. No. 10605, February 17, 2016

BIENVENIDO T. CANLAPAN, Complainant, v. ATTY. WILLIAM B. BALAYO, Respondent.
A.C. No. 10945 (Formerly CBD 09-2507), February 23, 2016
ANGELITO RAMISCAL AND MERCEDES ORZAME, Complainants, v. ATTY. EDGAR S.
ORRO, Respondent.
Facts:
The respondent did not inform the Ramiscals of the adverse decision of the CA which they only
learned about from their neighbors.. They endeavored to communicate with the respondent but
their efforts were initially in vain. When they finally reached him, he asked an additional
P7,000.00 from them as his fee in filing a motion for reconsideration in their behalf, albeit
telling them that such motion would already be belated. . To their dismay, they later discovered
that he did not file the motion for reconsideration; hence, the decision attained finality,
eventually resulting in the loss of their property measuring 8.479 hectares with a probable
worth of P3,391,600.00
Issue:
WON the respondent did not competently and diligently discharge his duties as the lawyer of
the Ramiscal
Held
Every lawyer, upon becoming a member of the Philippine Bar, solemnly takes the Lawyer’s
Oath, by which he vows, among others, that: “I will delay no man for money or malice, and will
conduct myself as a lawyer according to the best of my knowledge and discretion, with all good
fidelity as well to the courts as to my clients.” If he should violate the vow, he contravenes the
Code of Professional Responsibility, particularly its Canon 17, and Rules 18.03 and 18.04 of
Canon 18, viz.: CANON 17 - A lawyer owes fidelity to the cause of his client and he shall be
mindful of the trust and confidence reposed in him. CANON 18 – A lawyer shall serve his client
with competence and diligence.Rule 18.03 – A lawyer shall not neglect a legal matter entrusted
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to him, and his negligence in connection therewith shall render him liable. Rule 18.04 – A
lawyer shall keep the client informed of the status of his case and shall respond within a
reasonable time to the client's request for information.
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A.C. No. 9574, June 21, 2016

MYRNA M. DEVEZA, Complainant, v. ATTY. ALEXANDER M. DEL PRADO,
Respondent.
FACTS:
Before the Court . Myrna M, Deveza (complainant) filed a disbarment case against
respondent Atty. Alexander M. Del Prado (Atty. Del Prado) for dishonesty and for acts
unbecoming a lawyer.
Respondent, Alexander del Prado bought a land from the complainant which is located
at Malvar St. Brgy. Camarin, Caloocan City with an area of 633.80 sq. m. covered by
Transfer Certificate of Title No. 178828 for P1,500 per square meters on installment
basis. To document the sale both parties executed a Contract to Sell wherein Atty. Del
Prado took all the copies on the pretext that he will have the document notarized but he
never gave a copy of the said document to the complainant. Eventually, Atty. Del Prado
defaulted in his obligation by leaving a balance of P 565,950. Consequently,
complainant sent a demand letter to the respondent for the payment of the unpaid
obligation and/or rescission of the sale.
Upon receipt of the demand letter, respondent called respondent and told her to meet at
Jollibee, Munoz Branch for him to pay the unpaid balance. Respondent likewise asked
complainant to bring the title of the property.
In the meeting, respondent brought a completely filled up Deed of Sale where he asked
the complainant to sign it before he will give the full payment. Afterwich, Atty. Del Prado
gave the complainant only P 5,000 and told her that the complete payment will be given
once the document has been notarized. However, Atty. Del Prado never paid the
balance of the purchase price for the lot he bought from the complainant. Worst, Atty.
Del Prado used the Deed of Sale he made the complainant sign by means of fraud as
evidence in the civil case filed by the complainant against him for the rescission of the
contract that misled the court.
In a Resolution dated September 3, 2012 the Court required Atty. Del Prado to
comment on the complaint but he failed to do so. Thus, the Court issued a Resolution
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on November 18, 2013 to refer the complaint to the Integrated Bar of the Philippines for
investigation, report and recommendation.
When the mandatory conference was set only the counsel of the complainant appeared
despite due notice was given to the respondent. Atty. Del Prado did not heed to the
order of the IBP.
The IBP issued its Report and Recommendation on September 2, 2014 stating that
Atty. Del Prado’s failure to answer complaint despite notices and his continuous
absence on the scheduled hearings shows his flouting resistance to the lawful orders of
the court and illustrates his despciency for his oath of office as a lawyer. The IBP-CBD
recommended that Atty. Del Prado be meter the penalty of suspension from practice of
law and as member of the bar for a period of 2 years.
In its Notice of Resolution No. XXI-2015-014, dated January 30, 2015, the IBP-Board of
Governors adopted and approved with modification the report and recommendation of
the CBD and suspended Atty. Del Prado from the practice of law for a period of five (5)
years.
The Court agrees with the findings and recommendation of the IBP.
ISSUE:
Whether or not respondent Atty. Alexander Del Prado is guilty of violating Rule 1.01 of
Canon 1 and Canon 7 of the Code of Professional Responsibility.
HELD:
Canon 7 of the Code of Professional Responsibility specifically mandates all lawyers to

uphold the integrity and dignity of the legal profession. Rule 1.01 of Canon 1 of the
same code prescribes a lawyer from engaging in any unlawful, dishonest, immoral or
deceitful conduct. They should refrain from doing any act which might lessen in any
degree the confidence and trust reposed by the public in the fidelity, honesty and
integrity of the legal profession.chanrobleslaw
In the present case, Atty. Del Prado committed an act which fell short of the standard of
the norm of conduct required of every lawyer. He deceived the complainant by making
her sign the deed of sale and making her believe that he would pay in full the balance of
the purchase price after he had the document notarized. Complainant waited for Atty.
Del Prado to make good his promise to pay but despite several demands, he continued
reneging on his obligation which prompted her to file a case against him.
Moreover, Atty. Del Prado wantonly disregarded the lawful orders of the Court and IBP-
CBD to file his comment and position paper and to appear in the mandatory conference
14
despite due notice. His continued defiance of the orders of the Court and the IBP-CBD
is a deliberate and contemptuous affront on the court's authority which cannot be
tolerated. Atty. Del Prado should bear in mind that he is a lawyer and an officer of the
court who is duty bound to obey and respect the court processes. He must
acknowledge, at all times, the orders of the Court and the IBP-CBD in deference to their
authority over him as a member of the bar.
Respondent Atty. Alexander Del Prado was found GUILTY of violating Rule 1.01 of
Canon 1 and Canon 7 of the Code of Professional Responsibility, hereby was
suspended by the court from practice of law for Five (5) years effective upon receipt
of the decision with a warning that a repetition of the same or a similar act will be dealt
with more severely.
xxxxxxx
PEREZ VS. CATINDIG
A.C. No. 5816, March 10, 2015
FACTS:Atty. Tristan A. Catindig admitted to Dr. Elmar Perez that he was already wed to
Lily Corazon Gomez. Atty. Catindig told Dr. Perez that he was in the process of
obtaining a divorce in a foreign country to dissolve his marriage to Gomez, and that he
would eventually marry her once the divorce had been decreed. Consequently,
sometime in 1984, Atty. Catindig and Gomez obtained a divorce decree from the
Dominican Republic.
On July 14, 1984, Atty. Catindig married Dr. Perez in the State of Virginia in the United
States of America (USA).
Years later, Dr. Perez came to know that her marriage to Atty. Catindig is a nullity since
the divorce decree that was obtained from the Dominican Republic by the latter and
Gomez is not recognized by Philippine laws. Sometime in 1997, Dr. Perez reminded
Atty. Catindig of his promise to legalize their union by filing a petition to nullify his
marriage to Gomez.
Sometime in 2001, Dr. Perez alleged that she received an anonymous letter in the mail
informing her of Atty. Catindig’s scandalous affair with Atty. Baydo, and that sometime
15
later, she came upon a love letter written and signed by Atty. Catindig for Atty. Baydo
dated April 25, 2001. In the said letter, Atty. Catindig professed his love to Atty. Baydo,
promising to marry her once his “impediment is removed.”
On October 31, 2001, Atty. Catindig abandoned Dr. Perez and their son; he moved to
an upscale condominium in Salcedo Village, Makati City where Atty. Baydo was
frequently seen.
Atty. Catindig, in his Comment, admitted that he married Gomez on May 18, 1968. He
claimed, however, that immediately after the wedding, Gomez showed signs that she
was incapable of complying with her marital obligations. Eventually, their irreconcilable
differences led to their de facto separation in 1984.
Atty. Catindig claimed that Dr. Perez knew of the foregoing, including the fact that the
divorce decreed by the Dominican Republic court does not have any effect in the
Philippines.
Atty. Catindig claimed that his relationship with Dr. Perez turned sour. Eventually, he left
their home in October 2001 to prevent any acrimony from
developing.anroblesvirtuallawlibrary
He denied that Atty. Baydo was the reason that he left Dr. Perez.
For her part, Atty. Baydo denied that she had an affair with Atty. Catindig.
IBP – recommended the disbarment of Atty. Catindig for gross immorality, violation of
Rule 1.01, Canon 7 and Rule 7.03 of the Code of Professional Responsibility. Complaint
against Atty. Baydo – dismissed for dearth of evidence.
ISSUE:
WON the respondents committed gross immorality, which would warrant their
disbarment.
HELD:YES.
RATIO:The Code of Professional Responsibility provides:chanRoblesvirtualLawlibrary
16
Rule 1.01 – A lawyer shall not engage in unlawful, dishonest, immoral or deceitful
conduct.
Canon 7 – A lawyer shall at all times uphold the integrity and dignity of the legal
profession and support the activities of the Integrated Bar.
Rule 7.03 – A lawyer shall not engage in conduct that adversely reflects on his fitness to
practice law, nor should he, whether in public or private life, behave in a scandalous
manner to the discredit of the legal profession.cralawred
In this regard, Section 27, Rule 138 of the Rules of Court provides that a lawyer may be
removed or suspended from the practice of law, inter alia, for grossly immoral conduct.
“A lawyer may be suspended or disbarred for any misconduct showing any fault or
deficiency in his moral character, honesty, probity or good demeanor.” Immoral conduct
involves acts that are willful, flagrant, or shameless, and that show a moral indifference
to the opinion of the upright and respectable members of the community. Immoral
conduct is gross when it is so corrupt as to constitute a criminal act, or so unprincipled
as to be reprehensible to a high degree, or when committed under such scandalous or
revolting circumstances as to shock the community’s sense of decency. The Court
makes these distinctions, as the supreme penalty of disbarment arising from conduct
requires grossly immoral, not simply immoral, conduct.roblesvirtuallawlibrary
Contracting a marriage during the subsistence of a previous one amounts to a grossly

immoral conduct.
The facts gathered from the evidence adduced by the parties and, ironically, from Atty.
Catindig’s own admission, indeed establish a pattern of conduct that is grossly immoral;
it is not only corrupt and unprincipled, but reprehensible to a high degree.
Moreover, assuming arguendo that Atty. Catindig’s claim is true, it matters not that Dr.
17
Perez knew that their marriage is a nullity. The fact still remains that he resorted to
various legal strategies in order to render a façade of validity to his otherwise invalid
marriage to Dr. Perez. Such act is, at the very least, so unprincipled that it is
reprehensible to the highest degree.
Further, after 17 years of cohabiting with Dr. Perez, and despite the various legal
actions he resorted to in order to give their union a semblance of validity, Atty. Catindig
left her and their son. It was only at that time that he finally decided to properly seek the
nullity of his first marriage to Gomez. Apparently, he was then already entranced with
the much younger Atty. Baydo, an associate lawyer employed by his firm.
While the fact that Atty. Catindig decided to separate from Dr. Perez to pursue Atty.
Baydo, in itself, cannot be considered a grossly immoral conduct, such fact forms part of
the pattern showing his propensity towards immoral conduct. Lest it be misunderstood,
the Court’s finding of gross immoral conduct is hinged not on Atty. Catindig’s desertion
of Dr. Perez, but on his contracting of a subsequent marriage during the subsistence of
his previous marriage to Gomez.
Atty. Catindig’s subsequent marriage during the subsistence of his previous one
definitely manifests a deliberate disregard of the sanctity of marriage and the marital
vows protected by the Constitution and affirmed by our laws. By his own admission,
Atty. Catindig made a mockery out of the institution of marriage, taking advantage of his
legal skills in the process. He exhibited a deplorable lack of that degree of morality
required of him as a member of the bar, which thus warrant the penalty of disbarment.
There is insufficient evidence to prove the affair between the respondents.
As it is, the evidence that was presented by Dr. Perez to prove her claim was mere
allegation, an anonymous letter informing her that the respondents were indeed having
an affair and the purported love letter to Atty. Baydo that was signed by Atty. Catindig.
The Court has consistently held that in suspension or disbarment proceedings against
lawyers, the lawyer enjoys the presumption of innocence, and the burden of proof rests
upon the complainant to prove the allegations in his complaint. The evidence required in
18
suspension or disbarment proceedings is preponderance of evidence.
DISPOSITION: Catindig – disbarred. Baydo – dismissed.
xxxxxxx
A.C. No. 10676, September 08, 2015

ATTY. ROY B. ECRAELA, Complainant, v. ATTY. IAN RAYMOND A.
PANGALANGAN, Respondent.
Facts:
This is a case for disbarment against Atty. Pangalangan for his illicit relations, chronic
womanizing, abuse of authority as an educator, and "other unscrupulous activities"
which cause "undue embarrassment to the legal profession."
Complainant and respondent were best friends and both graduated from the University
of the Philippines (UP) College of Law in 1990, where they were part of a peer group or
barkada with several of their classmates. After passing the bar examinations and being
admitted as members of the Bar in 1991, they were both registered with the IBP
Quezon City.
Respondent was formerly married to Sheila P. Jardiolin (Jardiolin) with whom he has
three (3) children. Complainant avers that while married to Jardiolin, respondent had a
series of adulterous and illicit relations with married and unmarried women between the
years 1990 to 2007. These alleged illicit relations involved:
1. AAA, who is the spouse of a colleague in the UP College of Law, from

1990 to 1992, which complainant had personal knowledge of such illicit
relations;
2. BBB, sometime during the period from 1992 to 1994 or from 1994 to 1996,
despite being already married to Jardiolin;
3. CCC, despite being married to Jardiolin and while also being romantically
involved with DDD;
4. DDD, sometime during the period from 2000 to 2002, despite still being
married to Jardiolin and while still being romantically involved with CCC;
5. EEE, who is related to complainant, sometime during the period from May
2004 until the filing of the Petition, while still being romantically involved
with CCC.
19
Issue:
Should Atty. Pangalangan be disbarred?
Ruling:
Atty. Pangalangan was disbarred by the SC for grossly immoral conduct.
CANON 1 - A LAWYER SHALL UPHOLD THE CONSTITUTION, OBEY THE LAWS OF

THE LAND AND PROMOTE RESPECT FOR LAW AND LEGAL PROCESSES.
Rule 1.01 - A lawyer shall not engage in unlawful, dishonest, immoral or deceitful
conduct.
CANON 7 - A LAWYER SHALL AT ALL TIMES UPHOLD THE INTEGRITY AND

DIGNITY OF THE LEGAL PROFESSION AND SUPPORT THE ACTIVITIES OF THE
INTEGRATED BAR.
Rule 7.03 - A lawyer shall not engage in conduct that adversely reflects on his fitness to
practice law, nor shall he, whether in public or private life. behave in a scandalous
manner to the discredit of the legal profession.
The practice of law is a privilege given to those who possess and continue to possess
the legal qualifications for the profession. Good moral character is not only required for
admission to the Bar, but must also be retained in order to maintain one's good standing
in this exclusive and honored fraternity.
In the case at bar, complainant alleged that respondent carried on several adulterous
and illicit relations with both married and unmarried women between the years 1990 to
2007, including complainant's own wife. Through documentary evidences in the form of
email messages, as well as the corroborating testimonies of the witnesses presented,
complainant was able to establish respondent's illicit relations with DOD and CCC by
preponderant evidence.
In sum, Atty. Pangalangan displayed deplorable arrogance by making a mockery out of

the institution of marriage, and taking advantage of his legal skills by attacking the
Petition through technicalities and refusing to participate in the proceedings. His actions
20
showed that he lacked the degree of morality required of him as a member of the bar,
thus warranting the penalty of disbarment.
xxxxxxx
PETITION FOR AUTHORITY TO CONTINUE USE OF THE FIRM NAME “SYCIP,

SALAZAR, FELICIANO, HERNANDEZ & CASTILLO".
PETITION FOR AUTHORITY TO CONTINUE USE OF THE FIRM NAME “SYCIP,

SALAZAR, FELICIANO, HERNANDEZ & CASTILLO.”
July 30, 1979
Facts:
Petitions were filed by the surviving partners of Atty. Alexander Sycip, who died on May 5,
1975 and by the surviving partners of Atty. Herminio Ozaeta, who died on February 14, 1976,
praying that they be allowed to continue using, in the names of their firms, the names of partners
who had passed away.
Petitioners contend that the continued use of the name of a deceased or former partner when
permissible by local custom, is not unethical but care should be taken that no imposition or
deception is practiced through this use. They also contend that no local custom prohibits the
continued use of a deceased partner’s name in a professional firm’s name; there is no custom or
usage in the Philippines, or at least in the Greater Manila Area, which recognizes that the name
of a law firm necessarily identifies the individual members of the firm.
Issue:
WON the surviving partners may be allowed by the court to retain the name of the partners who
already passed away in the name of the firm? NO
Held:
In the case of Register of Deeds of Manila vs. China Banking Corporation, the SC said:
The Court believes that, in view of the personal and confidential nature of the relations between
attorney and client, and the high standards demanded in the canons of professional ethics, no
practice should be allowed which even in a remote degree could give rise to the possibility of
deception. Said attorneys are accordingly advised to drop the names of the deceased partners
from their firm name.
The public relations value of the use of an old firm name can tend to create undue advantages
and disadvantages in the practice of the profession. An able lawyer without connections will
have to make a name for himself starting from scratch. Another able lawyer, who can join an old
firm, can initially ride on that old firm’s reputation established by deceased partners.
The court also made the difference from the law firms and business corporations:
A partnership for the practice of law is not a legal entity. It is a mere relationship or association
for a particular purpose. … It is not a partnership formed for the purpose of carrying on trade or
business or of holding property.” Thus, it has been stated that “the use of a nom de plume,
assumed or trade name in law practice is improper.
We find such proof of the existence of a local custom, and of the elements requisite to constitute
21
the same, wanting herein. Merely because something is done as a matter of practice does not
mean that Courts can rely on the same for purposes of adjudication as a juridical custom.
Petition suffers legal and ethical impediment.
xxxxxxx
Bumactao v Fano AC 10286
In failing to accurately state his professional details, respondent already committed punishable
violations. An isolated inaccuracy, regardless of the concerned lawyer's lack of bad faith, already
merits a penalty of relative severity. In Bumactao v. Fano,58 respondent Atty. Restito F. Fano
was suspended from the practice of law for the singular violation of indicating wrong MCLE
compliance details:
Here, it is established that respondent Atty. Restito F. Fano falsely indicated "MCLE
Compliance No. III-0018308". . . . . The admitted falsity notwithstanding, respondent endeavors
to douse his culpability by shifting the blame to the MCLE providers - PLM and IBP Quezon
City Chapter — and insisting that he acted in good faith. He likewise attributes the indication of
"MCLE Compliance No. III-0018308" to his secretary / liaison, an "honest mistake . . . because
of the pressure of his many duties."
We are not impressed.
Bar Matter No. 1922, dated June 3, 2008, requires "practicing members of the bar to indicate in
all pleadings filed before the courts or quasi-judicial bodies, the number and date of issue of their
MCLE Certificate of Compliance or Certificate of Exemption, as may be applicable. . . ." It
further provides that "[f]ailure to disclose the required information would cause the dismissal of
the case and the expunction of the pleadings from the records."
At the very least, respondent was negligent in failing to monitor his own MCLE compliance.
This is a sort of negligence that is hardly excusable. As a member of the legal profession,
respondent ought to have known that non-compliance would have resulted in the rendering
inutile of any pleading he may file before any tribunal. The grave consequence of non-
compliance notwithstanding, respondent (by his own account) admits to having complacently
relied on the statements of MCLE providers. His negligence, therefore risked harm not only upon
himself - he being now burdened with the present complaint as a direct consequence - but worse,
upon his clients, the reliefs they seek through their pleadings being possibly rendered
inoperative.59
This court has never shied away from disciplining lawyers who have willfully engaged in acts of
deceit and falsehood.
xxxxxxx
22
INTESTATE ESTATE OF JOSE UY, HEREIN REPRESENTED BY ITS
ADMINISTRATOR WILSONUY v. ATTY. PACIFICO M. MAGHARI III
A.C. NO. 10525
September 01, 2015
Legal Ethics, Deceitful Conduct of a Lawyer; Lawyer’s Signature on the Pleading
A counsel's signature on a pleading is neither an empty formality nor even a mere means
for identification. Through his or her signature, a party's counsel makes a positive declaration. In
certifying through his or her signature that he or she has read the pleading, that there is ground to
support it, and that it is not interposed for delay, a lawyer asserts his or her competence,
credibility, and ethics. Signing a pleading is such a solemn component of legal practice that this
court has taken occasion to decry the delegation of this task to non-lawyers as a violation of the
Code of Professional Responsibility
A counsel's signature is such an integral part of a pleading that failure to comply with this
requirement reduces a pleading to a mere scrap of paper totally bereft of legal effect. Thus,
faithful compliance with this requirement is not only a matter of satisfying a duty to a court but is
as much a matter of fidelity to one's client. A deficiency in this respect can be fatal to a client's
cause.
The inclusion of a counsel's Roll of Attorneys number, professional tax receipt number,
and Integrated Bar of the Philippines (IBP) receipt (or lifetime membership) number is intended
to preserve and protect the integrity of legal practice. They seek to ensure that only those who
have satisfied the requisites for legal practice are able to engage in it. With the Roll of Attorneys
number, parties can readily verify if a person purporting to be a lawyer has, in fact, been
admitted to the Philippine bar.45 With the professional tax receipt number, they can verify if the
same person is qualified to engage in a profession in the place where he or she principally
discharges his or her functions. With the IBP receipt number, they can ascertain if the same
person remains in good standing as a lawyer.
Paying professional taxes (and the receipt that proves this payment) is likewise
compliance with a revenue mechanism that has been statutorily devolved to local government
units.
The inclusion of information regarding compliance with (or exemption from) Mandatory
Continuing Legal Education (MCLE) seeks to ensure that legal practice is reserved only for
those who have complied with the recognized mechanism for "keep[ing] abreast with law and
jurisprudence, maintaining] the ethics of the profession[,] and enhancing] the standards of the
practice of law.
Lastly, the inclusion of a counsel's address and contact details is designed to facilitate the
dispensation of justice. These pieces of information aid in the service of court processes, enhance
compliance with the requisites of due process, and facilitate better representation of a client's
cause.
23
These requirements are not mere frivolities. They are not mere markings on a piece of
paper. To willfully disregard them is, thus, to willfully disregard mechanisms put in place to
facilitate integrity, competence, and credibility in legal practice; it is to betray apathy for the
ideals of the legal profession and demonstrates how one is wanting of the standards for
admission to and continuing inclusion in the bar. Worse, to not only willfully disregard them but
to feign compliance only, in truth, to make a mockery of them reveals a dire, wretched, and utter
lack of respect for the profession that one brandishes.
It is unsettling that respondent engaged in the mockery and ridicule that he did of the very
same badges—his place in the Roll of Attorneys, his membership in the Integrated Bar, his
recognition as a practicing professional, his continuing training and competence—that are
emblematic of his being a lawyer. Seeing as how he manifested such contempt for these badges,
we find that there is every reason for preventing him, at least temporarily, from engaging in the
profession these badges signify.
xxxxxxx
Samuel Arnado v Atty. Homobono A. Adaza
FACTS:
Atty. Arnado called the attention of the Court to the practice of Atty. Adaza of
indicating “MCLE application for exemption under process” in his pleadings for the years
2009-2012, and “MCLE Application for Exemption for Reconsideration” in a pleading
filed in 2012. Arnado inquired from the MCLE office about the status of Atty. Adaza’s
compliance and found out that the latter has not complied with the MCLE requirement
for 3 consecutive compliance periods or from the year 2001-2010 and that his
Application for Exemption was denied in 2009.
The court directed that Atty. Adaza be furnished a copy of Atty. Arnado’s
complaint and to file his comment within 10 days from notice. Respondent contended
that he did not receive a copy of the denial of his application and was wondering why
his application cannot be granted. He stated his achievements as a lawyer, the books
he wrote and claimed that he had been practicing law for about 50 years.
The OBC in its report stated that respondent filed an application for exemption for
the first 2 compliance period but was denied because he failed to submit sufficient,
satisfactory and convincing proof to establish his expertise in a certain area of law. The
MCLE office has no record that respondent filed a motion for reconsideration thus his
representation in his pleading is baseless.
The OBC recommended that respondent be declared a delinquent member of

the Bar and guilty of non-compliance with the MCLE requirements, suspension from the
practice of law for six months with a stem waming that a repetition of the same or similar
act in the future will be dealt with more severely and that he be directed to comply with
the requirements set forth by the MCLE Goveming Board.
24
ISSUE:
Whether respondent is administratively liable for his failure to comply with the
MCLE requirements.
HELD:
Clearly, respondent had been remiss in his responsibilities by failing to comply
with the MCLE requirement. 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 furnished the Court with his
letter asking the office to act on his application for exemption but alleged that his
secretary failed to send it to the MCLE Office. He did not comply with the Fourth
Compliance Period. Respondent's failure to comply with the MCLE requirements
jeopardized the causes of his clients because the pleadings he filed could be stricken
off from the records and considered invalid.
Respondent's failure to comply with the MCLE requirements and disregard of the
directives of the MCLE Office warrant his declaration as a delinquent member of the IBP
While the MCLE Implementing Regulations state that the MCLE Committee should
recommend to the IBP Board of Governors the listing of a lawyer as a delinquent
member, there is nothing that prevents the Court from using its administrative power
and supervision to discipline erring lawyers and from directing the IBP Board of
Governors to declare such lawyers as delinquent members of the IBP.
The Court DECLARED Atty. Homobono A. Adaza as a delinquent member of the

Integrated Bar of the Philippines and SUSPENDED him from the practice of law for 6
MONTHS, or until he has fully complied with the MCLE requirements for the First,
Second, Third, and Fourth Compliance Periods, whichever is later, and he has fully paid
the required non-compliance and reinstatement fees.
xxxxxxx
PCGG V SANDIGANBAYAN
FACTS
In 1976 the General Bank and Trust Company (GENBANK) encountered financial difficulties.
GENBANK had extended considerable financial support to Filcapital Development Corporation
causing it to incur daily overdrawings on its current account with Central Bank. Despite the
mega loans GENBANK failed to recover from its financial woes. The Central Bank issued a
resolution declaring GENBANK insolvent and unable to resume business with safety to its
depositors, creditors and the general public, and ordering its liquidation. A public bidding of
GENBANK’s assets was held where Lucio Tan group submitted the winning bid. Solicitor
General Estelito Mendoza filed a petition with the CFI praying for the assistance and supervision
of the court in GENBANK’s liquidation as mandated by RA 265. After EDSA Revolution I Pres
25
Aquino established the PCGG to recover the alleged ill-gotten wealth of former Pres Marcos, his
family and cronies. Pursuant to this mandate, the PCGG filed with the Sandiganbayan a
complaint for reversion, reconveyance, restitution against respondents Lucio Tan, at.al. PCGG
issued several writs of sequestration on properties allegedly acquired by them by taking
advantage of their close relationship and influence with former Pres. Marcos. The
abovementioned respondents Tan, et. al are represented as their counsel, former Solicitor
General Mendoza. PCGG filed motions to disqualify respondent Mendoza as counsel for
respondents Tan et. al. with Sandiganbayan. It was alleged that Mendoza as then Sol Gen and
counsel to Central Bank actively intervened in the liquidation of GENBANK which was
subsequently acquired by respondents Tan et. al., which subsequently became Allied Banking
Corporation. The motions to disqualify invoked Rule 6.03 of the Code of Professional
Responsibility which prohibits former government lawyers from accepting “engagement” or
employment in connection with any matter in which he had intervened while in the said service.
The Sandiganbayan issued a resolution denyting PCGG’s motion to disqualify respondent
Mendoza. It failed to prove the existence of an inconsistency between respondent Mendoza’s
former function as SolGen and his present employment as counsel of the Lucio Tan
group. PCGGs recourse to this court assailing the Resolutions of the Sandiganbayan.
ISSUE
Whether Rule 6.03 of the Code of Professional Responsibility applies to respondent Mendoza.
The prohibition states: “A lawyer shall not, after leaving government service, accept engagement
or employment in connection with any matter in which he had intervened while in the said
service.”
HELD
The case at bar does not involve the “adverse interest” aspect of Rule 6.03. Respondent
Mendoza, it is conceded, has no adverse interest problem when he acted as SOlGen and later as
counsel of respondents et.al. before the Sandiganbayan. However there is still the issue of
whether there exists a “congruent-interest conflict” sufficient to disqualify respondent Mendoza
from representing respondents et. al. The key is unlocking the meaning of “matter” and the metes
and bounds of “intervention” that he made on the matter. Beyond doubt that the “matter” or the
act of respondent Mendoza as SolGen involved in the case at bar is “advising the Central Bank,
on how to proceed with the said bank’s liquidation and even filing the petition for its liquidation
in CFI of Manila. The Court held that the advice given by respondent Mendoza on the procedure
to liquidate GENBANK is not the “matter” contemplated by Rule 6.03 of the Code of
Professional Responsibility. ABA Formal Opinion No. 342 is clear in stressing that “drafting,
enforcing or interpreting government or agency procedures, regulations and laws, or briefing
abstract principles of law are acts which do not fall within the scope of the term “matter” and
cannot disqualify. Respondent Mendoza had nothing to do with the decision of the Central Bank
to liquidate GENBANK. He also did not participate in the sale of GENBANK to Allied Bank.
The legality of the liquidation of GENBANK is not an issue in the sequestration cases. Indeed,
the jurisdiction of the PCGG does not include the dissolution and liquidation of banks. Thus, the
Code 6.03 of the Code of Professional Responsibility cannot apply to respondent Mendoza
because his alleged intervention while SolGen is an intervention on a matter different from the
26
matter involved in the Civil case of sequestration. In the metes and bounds of the “intervention”.
The applicable meaning as the term is used in the Code of Professional Ethics is that it is an act
of a person who has the power to influence the subject proceedings. The evil sought to be
remedied by the Code do not exist where the government lawyer does not act which can be
considered as innocuous such as “ drafting, enforcing, or interpreting government or agency
procedures, regulations or laws or briefing abstract principles of law.” The court rules that the
intervention of Mendoza is not significant and substantial. He merely petitions that the court
gives assistance in the liquidation of GENBANK. The role of court is not strictly as a court of
justice but as an agent to assist the Central Bank in determining the claims of creditors. In such a
proceeding the role of the SolGen is not that of the usual court litigator protecting the interest of
government.
Petition assailing the Resolution of the Sandiganbayan is denied.
Relevant Dissenting Opinion of Justice Callejo:
Rule 6.03 is a restatement of Canon 36 of the Canons of Professional Ethics: “ A lawyer, having
once held public office or having been in the public employ, should not after his retirement
accept employment in connection with any matter which he has investigated or passed upon
while in such office or employ.”
Indeed, the restriction against a public official from using his public position as a vehicle to
promote or advance his private interests extends beyond his tenure on certain matters in which he
intervened as a public official. Rule 6.03 makes this restriction specifically applicable to lawyers
who once held public office.” A plain reading shows that the interdiction 1. applies to a lawyer
who once served in the government and 2. relates to his accepting “engagement or employment”
in connection with any matter in which he had intervened while in the service.
xxxxxxx
Catu vs. Rellosa [A.C. No. 5738. February 19, 2008]

16 Aug
Ponente: CORONA, J.
FACTS:
Complainant Wilfredo M. Catu is a co-owner of a lot and the building erected thereon located in
Manila. His mother and brother contested the possession of Elizabeth C. Diaz-Catu and Antonio
Pastor of one of the units in the building. The latter ignored demands for them to vacate the
premises. Thus, a complaint was initiated against them in the Lupong Tagapamayapa of
Barangay. Respondent, as punong barangay, summoned the parties to conciliation
meetings. When the parties failed to arrive at an amicable settlement, respondent issued a
certification for the filing of the appropriate action in court.Respondent entered his appearance as
counsel for the defendants in the (subsequent ejectment) case. Complainant filed the instant
administrative complaint, claiming that respondent committed an act of impropriety as a lawyer
and as a public officer when he stood as counsel for the defendants despite the fact that he
presided over the conciliation proceedings between the litigants as punong barangay.
27
ISSUE:
Whether or not Atty. Rellosa violated the Code of Professional Responsibility.
HELD:
YES. Respondent suspended for six (6) months.
RATIO:
[R]espondent was found guilty of professional misconduct for violating his oath as a lawyer and
Canons 1 and 7 and Rule 1.01 of the Code of Professional Responsibility.
A civil service officer or employee whose responsibilities do not require his time to be fully at
the disposal of the government can engage in the private practice of law only with the written
permission of the head of the department concerned in accordance with Section 12, Rule XVIII
of the Revised Civil Service Rules.
Respondent was strongly advised to look up and take to heart the meaning of the
word delicadeza
xxxxxxx
HEINZ R. HECK v. JUDGE ANTHONY E. SANTOS
401 SCRA 46 (2003)
Delegating to a counsel of one of the parties the preparation of a decision and parroting it
verbatim reflect blatant judicial sloth.
Heinz R. Heck is one of the defendants in a Civil Case before the Regional Trial presided by
Judge Anthony E. Santos. Heck and his co-defendant did not receive a copy of the order to
schedule the
trial on June 10 and 11, 1996. Consequently, they and their counsel failed to appear therein.
Since only the plaintiff’s counsel, Atty. Manuel Singson, appeared in that hearing, Judge Santos
considered the non-attendance of Heck and his co-defendant as waiver of their right to present
evidence. Judge Santos thereafter ordered that the case to be submitted for decision. He therefore
authorized Atty. Singson to prepare the draft of the decision.
The decision issued by Judge Santos was copied verbatim from the draft which Atty. Singson
prepared. Hence, Heck filed an administrative complaint charging Judge Santos with violation of
Section 1, Rule 36 of the Revised Rules of Court. The Office of the Court Administrator (OCA)
found Judge Santos guilty for adopting Singson’s work as his own.
28
ISSUE:
Whether or not Judge Santos is guilty of gross ignorance of the law
HELD:
The Court agrees with the findings of the OCA. Santos’ order for the counsel of one of the
parties to draft the decision and his adoption verbatim of the draft clearly violate the Code of
Judicial Conduct. The pertinent canons of which read: Canon 2, a Judge should avoid
impropriety and the appearance of impropriety in all activities. Canon 3, a Judge should perform
official duties honestly, and with impartiality and diligence adjudicative responsibilities.
By such order, Judge Santos abdicated a function exclusively granted to him by no less than the
fundamental law of the land. It is axiomatic that decision-making, among other duties, is the
primordial and most important duty of a member of the bench. He must use his own
perceptiveness in understanding and analyzing the evidence presented before him and his own
discernment when determining the proper action, resolution or decision. Delegating to a counsel
of one of the parties the preparation of a decision and parroting it verbatim reflect blatant judicial
sloth.
Lack of malice or bad faith is not an excuse. It bears emphasis that a judge must not only render
a just, correct and impartial decision. He should do so in such a manner as to be free from any
suspicion as to his fairness, impartiality and integrity.
xxxxxxx
AREOLA vs. ATTY. MENDOZA A.C. No. 10135 January 15,

2014
This refers to the administrative complaint1 filed by Edgardo D. Areola (Areola) a.k.a. Muhammad
Khadafy against Atty. Maria Vilma Mendoza (Atty. Mendoza), from the Public Attorney s Office (PAO) for
violation of her attorney s oath of office, deceit, malpractice or other gross misconduct in office under
Section 27, Rule 138 of the Revised Rules of Court, and for violation of the Code of Professional
Responsibility.
In the letter-complaint addressed to the Commission on Bar Discipline of the Integrated Bar of the
Philippines (IBP), Areola stated that he was filing the complaint in behalf of his co-detainees. He alleged
that, during Prisoners Week, Atty. Mendoza, visited the Jail and called all detainees with pending cases
before the RTC, where she was assigned, to attend her speech/lecture. Areola claimed that Atty.
Mendoza stated the following during her speech:
"O kayong may mga kasong drugs na may pangpiyansa o pang- areglo ay maging praktikal sana kayo
kung gusto ninyong makalaya agad. Upang makatiyak kayo na hindi masasayang ang pera ninyo ay sa
akin ninyo ibigay
o ng kamag-anak ninyo ang pera at ako na ang bahalang maglagay kay Judge Martin at Fiscal banqui; at
29
kayong mga detenidong mga babae na no bail ang kaso sa drugs, iyak-iyakan lang ninyo si Judge Martin
at palalayain na kayo. Malambot ang puso noon."3
Areola furthermore stated that when he helped his co-inmates in drafting their pleadings and filing motions
before the RTC, Atty. Mendoza undermined his capability.
Atty. Mendoza asseverated that the filing of the administrative complaint against her is a harassment tactic
by Areola.
The Investigating Commissioner stated that the Complainant is knowledgeable in the field of law. While he
may be of service to his fellow detainees, he must, however, be subservient to the skills and knowledge of
a full fledged lawyer. He however found no convincing evidence to prove that Atty. Mendoza received
money from Areola's co-detainees as alleged.
Nonetheless, Atty. Mendoza admitted in her Answer that she advised her clients and their relatives to
approach the judge and the fiscal "to beg and cry" so that their motions would be granted and their cases
against them would be dismissed. To the Investigating Commissioner, this is highly unethical and
improper as the act of Atty. Mendoza degrades the image of and lessens the confidence of the public in
the judiciary.12 The Investigating Commissioner recommended that Atty. Mendoza be suspended from the
practice of law for a period of two (2) months.13
ISSUE: Whether or not Atty. Mendoza is liable for giving improper advice to her clients in violation of Rule
1.02 and Rule 15.07 of the Code of Professional Responsibility.
HELD: Yes. The Court agrees with the IBP Board of Governors that Atty. Mendoza made irresponsible
advices to her clients in violation of Rule 1.02 and Rule 15.07 of the Code of Professional Responsibility.
It is the mandate of Rule 1.02 that "a lawyer shall not counsel or abet activities aimed at defiance of the
law or at lessening confidence in the legal system." Rule15.07 states that "a lawyer shall impress
upon his client compliance with the laws and the principles of fairness."
Atty. Mendoza's improper advice only lessens the confidence of the public in our legal system. Judges
must be free to judge, without pressure or influence from external forces or factors22 according to the
merits of a case. Atty. Mendoza's careless remark is uncalled for.
It must be remembered that a lawyer's duty is not to his client but to the administration of
justice.18wphi1 To that end, his client's success is wholly subordinate. His conduct ought to and must
always be scrupulously observant of the law and ethics. Any means, not honorable, fair and honest
which is resorted to by the lawyer, even in the pursuit of his devotion to his client's cause, is
condemnable and unethical.23
In spite of the foregoing, the Court deems the penalty of suspension for two (2) months as excessive and
not commensurate to Atty. Mendoza's infraction. Disbarment and suspension of a lawyer, being the most
severe forms of disciplinary sanction, should be imposed with great caution and only in those cases where
the misconduct of the lawyer as an officer of the court and a member of the bar is established by clear,
30
convincing and satisfactory proof.24 The Court notes that when Atty. Mendoza made the remark "Iyak-
iyakan lang ninyo si Judge Martin at palalayain na kayo. Malambot ang puso noon", she was not compelled
by bad faith or malice. While her remark was inappropriate and unbecoming, her comment is not
disparaging and reproachful so as to cause dishonor and disgrace to the Judiciary.
xxxxxxx
A.C. No. 11069, June 08, 2016

RONALDO C. FACTURAN, Complainant, v. PROSECUTOR ALFREDO L.
BARCELONA, JR., Respondent.
Facts:
The complainant alleged that on June 4, 2004 he filed a complaint for qualified
thief against Pilar Mendoza and four (4) others. The complaint was docketed as I.S No.
04-211. It was then forwarded to the herein respondent A prosecutor Barcelona for
approval. However, the failed to take necessary action for the complaint. Worst, he
removed the record and brought to his home. Later it was found out that one of the
accused was his relative.
Issue:
WON prosecutor Barcelona has violated the CPR?
Held:
The Supreme Court found Prosecutor Barcelona for violating Rule 6.02 Canon 6
of Code of Professional Responsibility. Therefore, he was suspended from the practice
of law for one (1) year. He was also sternly warned to a more severe penalty for
repeating the said act.
Supreme Court said, the respondent obstinately and deliberately refuse to
perform his duties which made the it advantage for the accused in I.S No. 4211.
xxxxxxx
BUNAGAN-BANSIG vs. ATTY. CELERA A.C. No. 5581. January 14,

2014
FACTS: Before this Court is a Petition for Disbarment filed by complainant Rose Bunagan-Bansig
(Bansig) against respondent Atty. Rogelio Juan A. Celera (respondent) for Gross Immoral Conduct.
On May 8, 1997, Respondent and Gracemarie R. Bunagan (Bunagan), sister of Bansig, entered into a
contract of marriage. Nonetheless, notwithstanding respondent's marriage with Bunagan, respondent
contracted another marriage on January 8, 1998 with a certain Ma. Cielo Paz Torres Alba.
Bansig alleged that respondent's act of contracting marriage with Alba, while his marriage is still
31
subsisting, constitutes grossly immoral and conduct unbecoming of a member of the Bar, which renders
him unfit to continue his membership in the Bar.
Thereafter, through several resolutions, respondent was required to file a comment on the petition.
However, respondent repeatedly failed to comply with the resolutions.
After investigation, the IBP-CBD, in its Report and Recommendation, recommended that respondent Atty.
Celera be suspended for a period of two (2) years from the practice of law.
ISSUE: Whether respondent is still fit to continue to be an officer of the court in the dispensation of justice.
HELD: No.
The Code of Professional Responsibility provides:

Rule 1.01- A lawyer shall not engage in unlawful, dishonest, immoral or deceitful conduct.
Canon 7- A lawyer shall at all times uphold the integrity and dignity of the legal profession, and
support the activities of the Integrated Bar.
Rule 7.03- A lawyer shall not engage in conduct that adversely reflects on his fitness to
practice law, nor should he, whether in public or private life, behave in a scandalous manner to
the discredit of the legal profession.
Respondent exhibited a deplorable lack of that degree of morality required of him as a member of the Bar.
He made a mockery of marriage, a sacred institution demanding respect and dignity. His act of contracting
a second marriage while his first marriage is subsisting constituted grossly immoral conduct and are
grounds for disbarment.
Moreover, respondent's cavalier attitude in repeatedly ignoring the orders of the Court constitutes utter
disrespect to the judicial institution. Respondent's conduct indicates a high degree of irresponsibility. His
obstinate refusal to comply with the Court's orders "not only betrays a recalcitrant flaw in his character; it
also underscores his disrespect of the Court's lawful orders which is only too deserving of reproof".
Considering respondent's propensity to disregard not only the laws of the land but also the lawful orders of
the Court, it only shows him to be wanting in moral character, honesty, probity and good demeanor. He is,
thus, unworthy to continue as an officer of the court. Wherefore, respondent is ordered DISBARRED
from the practice of law and his name stricken of the Roll of Attorneys.
xxxxxxx
A.C. No. 8210, August 08, 2016

SPOUSES MANOLO AND MILINIA NUEZCA, Complainants, v. ATTY. ERNESTO V.
VILLAGARCIA, Respondent.
Facts
In their verified complaint, complainants averred that respondent sent them a demand
letter2 dated February 15, 2009, copy furnished to various offices and persons, which
contained not only threatening but also libelous utterances. Allegedly, the demand letter
32
seriously maligned and ridiculed complainants to its recipients. Complainants likewise
posited that several news clippings3 that were attached to the demand letter were
intended to sow tear in them, and claimed that the circulation thereof caused them
sleepless nights, wounded feelings, and besmirched reputation. Thus, they maintained
that respondent should be held administratively liable therefor.
Issue: Whether or not atty. Villagarcia should be held administratively liable based on
the demand letter using words that maligned their character.
The Court's Ruling
The practice of law is a privilege given to lawyers who meet the high standards of legal
proficiency and morality. Any violation of these standards exposes the lawyer to
administrative liability.15 Rule 8.01, Canon 8 of the CPR
provides:ChanRoblesVirtualawlibrary
Rule 8.01. - A lawyer shall not, in his professional dealings, use language which is
abusive, offensive or otherwise improper.
In this case, the demand letter that respondent sent to complainants contained not
merely a demand for them to settle their monetary obligations to respondent's client, but
also used words that maligned their character. It also imputed crimes against
them, i.e., that they were criminally liable for worthless or bum checks and estafa.
WHEREFORE, respondent Arty. Ernesto V. Villagarcia is found GUILTY of violation of

Rule 8.01, Canon 8 of the Code of Professional Responsibility. He is
hereby SUSPENDED from the practice of law for a period of one (1) month, effective
upon his receipt of this Resolution, and is STERNLY WARNED that a repetition of the
same or similar acts will be dealt with more severely.
xxxxxxx
JOSE C. SABERON v. ATTY. FERNANDO T. LARONG
561 SCRA 493 (2008)
Utterances, petitions and motions are considered as absolutely privileged, however false or
malicious they may be, only if they are pertinent and relevant to the subject of inquiry.
33
Petitioner Jose C. Saberon charged respondent Atty. Fernando T. Larong of grave misconduct for
allegedly using abusive and offensive language in pleadings filed before the Bangko Sentral ng
Pilipinas (BSP).
The Investigation Commissioner found Larong guilty of grave misconduct, Saberon nevertheless
submits that the recommended penalty of suspension should be modified to disbarment. On the
other hand, Larong seeks for the Court‘s declaration that the questioned allegations were
privileged communication. He submits that the statements, while opening up a lawyer to possible
administrative sanction for the use of intemperate language under the Canons of Professional
Responsibility, should not be stripped of their privileged nature.
ISSUES:
Whether or not Larong is guilty of grave misconduct
HELD:
On many occasions, the Court has reminded members of the Bar to abstain from all offensive
personality and to advance no fact prejudicial to the honor or reputation of a party or witness,
unless required by the justice of the cause with which he is charged. In keeping with the dignity
of the legal profession, a lawyer’s language even in his pleadings must be dignified.
Respecting Larong’s argument that the matters stated in the Answer he filed before the BSP were
privileged, it suffices to stress that lawyers, though they are allowed a latitude of pertinent
remark or comment in the furtherance of the causes they uphold and for the felicity of their
clients, should not trench beyond the bounds of relevancy and propriety in making such remark
or comment.
True, utterances, petitions and motions made in the course of judicial proceedings have
consistently been considered as absolutely privileged, however false or malicious they may be,
but only for so long as they are pertinent and relevant to the subject of inquiry.
Thus, while Larong is guilty of using infelicitous language, such transgression is not of a
grievous character as to merit Larong’s disbarment. In light of Larong’s apologies, the Court
finds it best to temper the penalty for his infraction which, under the circumstances, is considered
simple, rather than grave, misconduct.
xxxxxxx
A.C. No. 10303 April 22, 2015
JOY A. GIMENO, Complainant,

vs.
ATTY. PAUL CENTILLAS ZAIDE, Respondent
34
FACTS: On August 8, 2007, complainant Joy A. Gimeno (Cimeno) filed a complaint3 with the
IBP's Commission on Bar Discipline, charging Atty. Zaide with: (1) usurpation of a notary
public's office; (2) falsification; (3) use of intemperate, offensive and abusive language; and (4)
violation of lawyer-client trust. In her complaint, Gimeno alleged that even before Atty. Zaide's
admission to the Bar and receipt of his notarial commission, he had notarized a partial
extrajudicial partition with deed of absolute sale on March 29, 2002. She also accused Atty.
Zaide of making false and irregular entries in his notarial registers.
On October 4, 2007, the IBP CBD issued an order setting the case for mandatory conference.
Commissioner Pedro A. Magpayo, Jr. (Commissioner Magpayo) found Atty. Zaide
administratively liable for violating the Notarial Practice Rules, representing conflicting
interests, and using abusive and insulting language in his pleadings.
He noted that Atty. Zaide violated Section 1(a) and 1(b), Rule VI of the Notarial Practice Rules
when he maintained several active notarial registers in different offices. These provisions
respectively require a notary public to "keep, maintain, protect and provide for lawful inspection,
a chronological official register of notarial acts consisting of a permanently bound book with
numbered papers" and to "keep only one active notarial register at any given time.
Finally, the investigating commissioner noted that Atty. Zaide used intemperate, offensive, and
abusive language when he called Gimeno a "notorious extortionist" in one of his pleadings.
ISSUE: Whether or not Atty. Zaide violated Section 1(a) and 1(b), Rule VI of the Notarial
Practice Rules when he maintained several active notarial registers in different offices and
violated Notarial Practice Rules.
HELD: YES. The Notarial Practice Rules strictly requires anotary public to maintain only one
(1) active notarial register andensure that the entries in it are chronologically arranged. The
“oneactive notarial register” rule is in place to deter a notary public from assigning several
notarial regiters to different offices manned by assistants who perform notarial services on his
behalf.
Since a notarial commission is personal to each lawyer, the notary public must also personally
administer the notarial acts29 that the law authorizes him to execute. This important duty is
vested with public interest. Thus, no other person, other than the notary public, should perform it.
This Court stresses that a notary public should not trivialize his functions as his powers and
duties are impressed with public interest. A Notary public's office is not merely an income-
generating venture. It is a public duty that each lawyer who has been privileged to receive a
notarial commission must faithfully and conscientiously perform.
Atty. Zaide should have been acutely aware of the requirements of his notarial commission. His
flagrant violation of Section 1, Rule VI of the Notarial Practice Rules is not merely a simple and
excusable negligence. It amounts to a clear violation of Canon 1 of the Code of Professional
35
Responsibility, which provides that "a lawyer [should] uphold the constitution, obey the laws of
the land and promote respect for law and legal processes." The prohibition on the use of
intemperate, offensive and abusive language in a lawyer's professional dealings, whether with
the courts, his clients, or any other person, is based on the following canons and rules of the
Code of Professional Responsibility:
Canon 8 - A lawyer shall conduct himself with courtesy, fairness and candor toward his
professional colleagues, and shall avoid harassing tactics against opposing counsel.
Rule 8.01 - A lawyer shall not, in his professional dealings, use language which is
abusive, offensive or otherwise improper.
Canon 11 - A lawyer shall observe and maintain the respect due to the courts and to
judicial officers and should insist on similar conduct by others.
Rule 11.03 - A lawyer shall abstain from scandalous, offensive or menacing language or
behavior before the Courts. (emphasis supplied)
As shown in the record, Atty. Zaide,in the reply that he drafted in the Ombudsman case, called
Gimeno a "notorious extortionist." And in another case, Gimeno observed that Atty. Zaide used
the following demeaning and immoderate language in presenting his comment against his
opposing counsel.
Her declaration in Public put a shame, DISGRACE, INDIGNITY AND HUMILIATION in the
whole Justice System, and the Department of Justice in particular, where the taxpayers paid for
her salary over her incompetence and poor performance as a prosecutor...This is a clear
manifestation that the Public prosecutor suffers serious mental incompetence as regard her
mandate as an Assistant City Prosecutor.35 (emphasis supplied)
This clearly confirms Atty. Zaide's lack of restraint in the use and choice of his words - a conduct
unbecoming of an officer of the court.
While a lawyer is entitled to present his case with vigor and courage, such enthusiasm does not
justify the use of offensive and abusive language. Language abounds with countless possibilities
for one to be emphatic but respectful, convincing but not derogatory, and illuminating but not
offensive.36
On many occasions, the Court has reminded the members of the Bar to abstain from any
offensive personality and to refrain from any act prejudicial to the honor or reputation of a party
or a witness. In keeping with the dignity of the legal profession, a lawyer's language even in his
pleadings, must be dignified.
xxxxxxx
MAXIMINO NOBLE III, Complainant, v. ATTY. ORLANDO O. AILES, Respondent.
PERLAS-BERNABE, J. | A.C. No. 10628 | July 01, 2015
36
 Noble III alleged that Ailes, a lawyer, filed a complaint for damages against his own brother,
Marcelo O. Ailes, Jr. (Marcelo), whom Maximino represented, together with other
defendants, therein. In the said complaint, Ailes stated the following data: "IBP-774058-
12/07/09-QC x x x MCLE Compliance No. II-00086893/Issued on March 10, 2008."
 Noble claimed that at the time of the filing of the said complaint, Ailes' IBP O.R. number
should have already reflected payment of his IBP annual dues for the year 2010, not 2009,
and that he should have finished his third Mandatory Continuing Legal Education (MCLE)
Compliance, not just the second.
Sometime in December 2011, Noble learned from Marcelo that the latter had filed a
separate case for grave threats and estafa against Ailes. When Noble was furnished a copy
of the complaint, he discovered that, through text messages, Ailes had been maligning him
and dissuading Marcelo from retaining his services as counsel, claiming that he was
incompetent and that he charged exorbitant fees, saying, among others: "x x x Better
dismiss [your] hi-track lawyer who will impoverish [you] with his unconscionable
[professional] fee. Max Noble, as shown in court records, never appeared even once, that's
why you lost in the pre-trial stage, x x x get rid of [Noble] as [your] lawyer. He is out to
squeeze a lot of money from [you], x x x daig mo nga mismong abogado mong polpol."
 Records show that Ailes even prepared a Notice to Terminate Services of Counsel in the
complaint for damages, which stated that Noble "x x x has never done anything to protect
the interests of the defendants in a manner not befitting his representation as a seasoned
law practitioner and, aside from charging enormous amount of professional fees and
questionable expenses. Affronted, Noble filed the instant complaint charging Orlando with
violation of Rule 7.03 of Canon 7, the entire Canon 8 of the Code of Professional
Responsibility (CPR) and prayed for the disbarment of respondent as well as the award of
damages.
AILES' DEFENSE:
1. His late submission of the third MCLE compliance is not a ground for disbarment and
that the Notice to Terminate Services of Counsel and Compromise Agreement were all
made upon the request of Marcelo when the latter was declared in default in the
aforementioned civil case.
2. The allegedly offensive language in his text messages sent to Marcelo was used in a
"brother-to-brother communication" and were uttered in good faith. irtualaw
Meanwhile, the criminal case for grave threats and estafa filed by Marcelo against Ailes
was downgraded to unjust vexation and Ailes was convicted of the crime of unjust
vexation, consisting in his act of vexing or annoying Marcelo by "texting insulting,
threatening and persuading words to drop his lawyer over a case x x x." ry
IBP Commissioner recommended the dismissal of the case against Orlando, finding that a
transgression of the MCLE compliance requirement is not a ground for disbarment as in fact,
failure to disclose the required information would merely cause the dismissal of the case and
37
the expunction of the pleadings from the records.
IBP Board of Governors adopted and approved the IBP Commissioner's Report and
Recommendation and dismissed the case against Orlando, warning him to be more circumspect
in his dealings.
ISSUE: whether or not the IBP correctly dismissed the complaint against Orlando.
HELD: PARTLY YES, PARTLY NO.
The practice of law is a privilege bestowed on lawyers who meet high standards of legal
proficiency and morality. Consequently, a lawyer mustat all times, whether in public or private
life, act in a manner beyond reproach especially when dealing with fellow lawyers.
In this relation, Rule 7.03 of Canon 7 as well as Canon 8 of the CPR provides:
chanRoblesvirtualLawlibrary
Rule 7.03 — A lawyer shall not engage in conduct that adversely reflects on his fitness to
practice law, nor shall he, whether in public or private life, behave in a scandalous manner to
the discredit of the legal profession.
chanroblesvirtuallawlibrary
Canon 8 — A lawyer shall conduct himself with courtesy, fairness and candor toward his
professional colleagues, and shall avoid harassing tactics against opposing counsel.
Rule 8.01 - A lawyer shall not, in his professional dealings, use language which is abusive,
offensive or otherwise improper.
Rule 8.02 - A lawyer shall not, directly or indirectly, encroach upon the professional
employment of another lawyer; however, it is the right of any lawyer, without fear or favor, to
give proper advice and assistance to those seeking relief against unfaithful or neglectful
counsel.
chanroblesvirtuallawlibrary
Though a lawyer's language may be forceful and emphatic, it should always be dignified and
respectful, befitting the dignity of the legal profession. The use of intemperate language and
unkind ascriptions has no place in the dignity of the judicial forum.23 In Buatis Jr. v. People,24 the
Court treated a lawyer's use of the words "lousy," "inutile," "carabao English," "stupidity," and
"satan" in a letter addressed to another colleague as defamatory and injurious which effectively
maligned his integrity. Similarly, the hurling of insulting language to describe the opposing
counsel is considered conduct unbecoming of the legal profession. library
In this case, the IBP found the text messages that Orlando sent to his brother Marcelo as casual
communications considering that they were conveyed privately. To the Court's mind, however,
the tenor of the messages cannot be treated lightly. The text messages were clearly intended to
malign and annoy Maximino, as evident from the use of the word "polpol" (stupid). Likewise,
Orlando's insistence that Marcelo immediately terminate the services of Maximino indicates
Orlando's offensive conduct against his colleague, in violation of the above-quoted rules.
Moreover, Orlando's voluntary plea of guilty to the crime of unjust vexation in the criminal case
38
filed against him by Marcelo was, for all intents and purposes, an admission that he spoke ill,
insulted, and disrespected Maximino - a departure from the judicial decorum which exposes
the lawyer to administrative liability.
While a lawyer is entitled to present his case with vigor and courage, such enthusiasm does not
justify the use of offensive and abusive language.
With regard to Orlando's alleged violation of BM No. 1922, the Court agrees with the IBP that
his failure to disclose the required information for MCLE compliance in the complaint for
damages he had filed against his brother Marcelo is not a ground for disbarment. At most, his
violation shall only be cause for the dismissal of the complaint as well as the expunction thereof
from the records. awlibrary
WHEREFORE, the Court finds respondent Atty. Orlando O. Ailes GUILTY of violating Rule 7.03 of
Canon 7 as well as the entire Canon 8 of the Code of Professional Responsibility. He is
herebyADMONISHED to be more circumspect in dealing with his professional colleagues
and STERNLY WARNED that a commission of the same or similar acts in the future shall be
dealt with more severely.
xxxxxxx
A.C. No. 7594, February 09, 2016

ADELPHA E. MALABED, Complainant, v. ATTY. MELJOHN B. DE LA PEÑA,
Respondent.
This case is an administrative complaint filed by Adelpha E. Malabed (complainant)

against Atty. Meljohn B. De la Peña (respondent) for dishonesty and grave misconduct.
The complainant claimed that the Certificate to File Action in the complaint filed by
respondent refers to a different complaint that is the complaint filed by complainant's
brother against Fortunato Jadulco. In effect, there was no Certificate to File Action,
which is required for the filing of a civil action, in the complaint filed by respondent on
behalf of his client Fortunato Jadulco. Morever, the complainant also alleged that
respondent did not furnish her counsel with a copy of the free patent covered by
Original Certificate of Title (OCT) No. 1730, but respondent forwarded a copy to the
Court of Appeals. Complainant claimed that she could not properly defend herself
without a copy of the title. She further claimed that the title presented by respondent
was fabricated.
ISSUE: Whether or not respondent is guilty of dishonesty and grave misconduct
39
RULING:
The court finds the respondent has committed gross misconduct for (1) misrepresenting
that he submitted a certificate to file action issued by the Lupon Tagapamayapa when in
fact there was none prior to the institution of the civil action of his client, Fortunato
Jadulco, in Civil Case No. B-1118; (2) using improper language in his pleadings; and (3)
defying willfully the Court's prohibition on reemployment in any government office as
accessory penalty of his dismissal as a judge. Gross misconduct is 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."chanIn view of respondent's repeated gross misconduct,
the court increased the IBP's recommended penalty to suspension from the practice of
law for two (2) years.
xxxxxxx
TAPAY ET AL v. ATTY. CHARLIE L. BANCOLO ET AL.

A.C. No. 96604, March 20, 2013
FACTS: Tapay and Rustia received an Order dated 14 October 2004 from the Office of the Ombudsman-
Visayas requiring them to file a counter-affidavit to a complaint for usurpation of authority, falsification of
public document, and graft and corrupt practices filed against them by Nehimias Divinagracia, Jr.
(Divinagracia), a co-employee in the Sugar Regulatory Administration. The Complaint1 dated 31 August
2004 was allegedly signed on behalf of Divinagracia by one Atty. Charlie L. Bancolo of the Jarder Bancolo
Law Office based in Bacolod City, Negros Occidental. When Atty. Bancolo and Rustia accidentally
chanced upon each other, the latter informed Atty. Bancolo of the case filed against them before the Office
of the Ombudsman. Atty. Bancolo denied that he represented Divinagracia since he had yet to meet
Divinagracia in person. When Rustia showed him the Complaint, Atty. Bancolo declared that the signature
appearing above his name as counsel for Divinagracia was not his. Thus, Rustia convinced Atty. Bancolo
to sign an affidavit to attest to such fact. On 9 December 2004, Atty. Bancolo signed an affidavit denying
his supposed signature appearing on the Complaint filed with the Office of the Ombudsman and submitted
six specimen signatures for comparison. Using Atty. Bancolo's affidavit and other documentary evidence,
Tapay and Rustia filed a counter-affidavit accusing Divinagracia of falsifying the signature of his alleged
counsel, Atty. Bancolo. The Office of the Ombudsman dismissed the criminal case for falsification of public
document for insufficiency of evidence. The administrative case for dishonesty was also dismissed for lack
of substantial evidence in a Decision dated 19 September
2005.
Tapay and Rustia filed with the Integrated Bar of the Philippines (IBP) a complaint to disbar Atty. Bancolo
and Atty. Jarder, Atty. Bancolo's law partner. The complainants alleged that they were subjected to a
harassment Complaint filed before the Office of the Ombudsman with the forged signature of Atty. Bancolo.
Complainants stated further that the signature of Atty. Bancolo in the Complaint was not the only one that
was forged. Complainants attached a Report6 dated 1 July 2005 by the Philippine National Police Crime
Laboratory 6 which examined three other letter-complaints signed by Atty. Bancolo for other clients,
40
allegedly close friends of Atty. Jarder. The report concluded that the questioned signatures in the letter-
complaints and the submitted standard signatures of Atty. Bancolo were not written by one and the same
person. Thus, complainants maintained that not only were respondents engaging in unprofessional and
unethical practices, they were also involved in falsification of documents used to harass and persecute
innocent people. They alleged that a certain Mary Jane Gentugao, the secretary of the Jarder Bancolo
Law Office, forged the signature of Atty. Bancolo.
Defendant's Defense:
Divinagracia filed his Counter-Affidavit dated 1 August 2005 denying that he falsified the signature of his
former lawyer, Atty. Bancolo. Divinagracia presented as evidence an affidavit dated 1 August 2005 by
Richard A. Cordero, the legal assistant of Atty. Bancolo, that the Jarder Bancolo Law Office accepted
Divinagracia's case and that the Complaint filed with the Office of the Ombudsman was signed by the
office secretary per Atty. Bancolo's instructions. Atty. Bancolo alleged that after being informed of the
assignment of the cases, he ordered his staff to prepare and draft all the necessary pleadings and
documents. However, due to some minor lapses, Atty. Bancolo permitted that the pleadings and
communications be signed in his name by the secretary of the law office. Respondents added that
complainants filed the disbarment complaint to retaliate against them since the cases filed before the
Office of the Ombudsman were meritorious and strongly supported by testimonial and documentary
evidence. Respondents also denied that Mary Jane Gentugao was employed as secretary of their law
office.
ISSUE: WON Atty. Bancolo violated the Code of Professional Responsibiliy.
HELD:
IBP's Recommendation:
Atty. Quisumbing found that Atty. Bancolo violated Rule 9.01 of Canon 9 of the Code of Professional
Responsibility while Atty. Jarder violated Rule 1.01 of Canon 1 of the same Code. The Investigating
Commissioner recommended that Atty. Bancolo be suspended for two years from the practice of law and
Atty. Jarder be admonished for his failure to exercise certain responsibilities in their law firm.
BOG's Decision:
The Board of Governors of the IBP approved with modification the Report and
Recommendation of the Investigating Commissioner. Atty. Bancolo shall be suspended for 1 year. The
charge against Atty. Jarder shall be dismissed for lack of merit.
After a careful review of the records of the case, the SC agreed with the findings and recommendation of
the IBP Board and find reasonable grounds to hold respondent Atty. Bancolo administratively liable. Atty.
Bancolo admitted that the Complaint he filed for a former client before the Office of the Ombudsman was
signed in his name by a secretary of his law office. Clearly, this is a violation of Rule 9.01 of Canon 9 of the
Code of Professional Responsibility.
xxxxxxx
TAPAY ET AL v. ATTY. CHARLIE L. BANCOLO ET AL.
41
A.C. No. 96604, March 20, 2013
FACTS: Tapay and Rustia received an Order dated 14 October 2004 from the Office of the Ombudsman-
Visayas requiring them to file a counter-affidavit to a complaint for usurpation of authority, falsification of
public document, and graft and corrupt practices filed against them by Nehimias Divinagracia, Jr.
(Divinagracia), a co-employee in the Sugar Regulatory Administration. The Complaint1 dated 31 August
2004 was allegedly signed on behalf of Divinagracia by one Atty. Charlie L. Bancolo of the Jarder Bancolo
Law Office based in Bacolod City, Negros Occidental. When Atty. Bancolo and Rustia accidentally
chanced upon each other, the latter informed Atty. Bancolo of the case filed against them before the Office
of the Ombudsman. Atty. Bancolo denied that he represented Divinagracia since he had yet to meet
Divinagracia in person. When Rustia showed him the Complaint, Atty. Bancolo declared that the signature
appearing above his name as counsel for Divinagracia was not his. Thus, Rustia convinced Atty. Bancolo
to sign an affidavit to attest to such fact. On 9 December 2004, Atty. Bancolo signed an affidavit denying
his supposed signature appearing on the Complaint filed with the Office of the Ombudsman and submitted
six specimen signatures for comparison. Using Atty. Bancolo's affidavit and other documentary evidence,
Tapay and Rustia filed a counter-affidavit accusing Divinagracia of falsifying the signature of his alleged
counsel, Atty. Bancolo. The Office of the Ombudsman dismissed the criminal case for falsification of public
document for insufficiency of evidence. The administrative case for dishonesty was also dismissed for lack
of substantial evidence in a Decision dated 19 September
2005.
Tapay and Rustia filed with the Integrated Bar of the Philippines (IBP) a complaint to disbar Atty. Bancolo
and Atty. Jarder, Atty. Bancolo's law partner. The complainants alleged that they were subjected to a
harassment Complaint filed before the Office of the Ombudsman with the forged signature of Atty.
Bancolo. Complainants stated further that the signature of Atty. Bancolo in the Complaint was not the only
one that was forged. Complainants attached a Report6 dated 1 July 2005 by the Philippine National
Police Crime Laboratory 6 which examined three other letter-complaints signed by Atty. Bancolo for other
clients, allegedly close friends of Atty. Jarder. The report concluded that the questioned signatures in the
letter-complaints and the submitted standard signatures of Atty. Bancolo were not written by one and the
same person. Thus, complainants maintained that not only were respondents engaging in unprofessional
and unethical practices, they were also involved in falsification of documents used to harass and
persecute innocent people. They alleged that a certain Mary Jane Gentugao, the secretary of the Jarder
Bancolo Law Office, forged the signature of Atty. Bancolo.
Defendant's Defense:
Divinagracia filed his Counter-Affidavit dated 1 August 2005 denying that he falsified the signature of his
former lawyer, Atty. Bancolo. Divinagracia presented as evidence an affidavit dated 1 August 2005 by
Richard A. Cordero, the legal assistant of Atty. Bancolo, that the Jarder Bancolo Law Office accepted
Divinagracia's case and that the Complaint filed with the Office of the Ombudsman was signed by the office
secretary per Atty. Bancolo's instructions. Atty. Bancolo alleged that after being informed of the assignment
of the cases, he ordered his staff to prepare and draft all the necessary pleadings and documents. However,
due to some minor lapses, Atty. Bancolo permitted that the pleadings and communications be signed in his
name by the secretary of the law office. Respondents added that complainants filed the disbarment complaint
to retaliate against them since the cases filed before the Office of the Ombudsman were meritorious and
strongly supported by testimonial and documentary evidence. Respondents also denied that Mary Jane
Gentugao was employed as secretary of their law office.
42
ISSUE: WON Atty. Bancolo violated the Code of Professional Responsibiliy.
HELD:
IBP's Recommendation:
Atty. Quisumbing found that Atty. Bancolo violated Rule 9.01 of Canon 9 of the Code of Professional
Responsibility while Atty. Jarder violated Rule 1.01 of Canon 1 of the same Code. The Investigating
Commissioner recommended that Atty. Bancolo be suspended for two years from the practice of law and
Atty. Jarder be admonished for his failure to exercise certain responsibilities in their law firm.
BOG's Decision:
The Board of Governors of the IBP approved with modification the Report and Recommendation of the
Investigating Commissioner. Atty. Bancolo shall be suspended for 1 year. The charge against Atty. Jarder
shall be dismissed for lack of merit. After a careful review of the records of the case, the SC agreed with the
findings and recommendation of the IBP Board and find reasonable grounds to hold respondent Atty.
Bancolo administratively liable. Atty. Bancolo admitted that the Complaint he filed for a former client before
the Office of the Ombudsman was signed in his name by a secretary of his law office. Clearly, this is a
violation of Rule 9.01 of Canon 9 of the Code of Professional Responsibility
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
ATTY. AURELIO C. ANGELES, JR., PROVINCIAL LEGAL OFFICER, BATAAN CAPITOL,

BALANGA CITY, BATAAN, Complainant, vs. ATTY. RENATO C. BAGAY, Respondent.
Legal Ethics; Canon 7; Canon 9
FACTS:
This case stemmed from the letter, dated June 11, 2008, submitted by Atty. Aurelio C.
Angeles, Jr. (Atty. Angeles, ]r.), the Provincial Legal Officer of Bataan, to Hon. Remigio M.
Escalada, Jr. (Executive ]udge), Executive Judge of the Regional Trial Court of Bataan against
Atty. Renato C. Bagay (respondent), for his alleged notarization of 18 documents at the time
he was out of the country from March 13, 2008 to April 8, 2008.
These documents were endorsed to the Provincial Legal Office by the Provincial Treasurer
who had information that they were notarized while respondent was outside the country
attending the Prayer and Life Workshop in Mexico. The letter contained the affidavits of the
persons who caused the documents to be notarized which showed a common statement
that they did not see respondent sign the documents himself and it was either the secretary
43
who signed them or the documents came out of the office already signed. Upon verification
with the Bureau of Immigration, it was found out that a certain Renato C. Bagay departed
from the country on March 13, 2008 and returned on April 8, 2008. The copy of the
Certification issued by the Bureau of Immigration was also attached to the letter.
44
The Report and Recommendation of Atty. Felimon C. Abelita III (Atty. Abelita III) as
Investigating Commissioner found that the letter of Atty. Angeles, Jr., dated June 11, 2008,
was not verified, that most of the attachments were not authenticated photocopies and that
the comment of respondent was likewise not verified. Atty. Abelita III, however, observed
that respondent’s signature on his comment appeared to be strikingly similar to the
signatures in most of the attached documents which he admitted were notarized in his
absence by his office secretary. He admitted the fact that there were documents that were
notarized while he was abroad and his signature was affixed by his office secretary who
was not aware of the import of the act. Thus, by his own admission, it was established that
by his negligence in employing an office secretary who had access to his office, his notarial
seal and records especially pertaining to his notarial documents without the proper
training, respondent failed to live up to the standard required by the Rules on Notarial
Practice.
Finding respondent guilty of negligence in the performance of his notarial duty which gave
his office secretary the opportunity to abuse his prerogative authority as notary public, the
Investigating Commissioner recommended the immediate revocation of respondent’s
commission as notary public and his disqualification to be commissioned as such for a
period of two (2) years.
The IBP Board of Governors adopted and approved the said recommendation in its
Resolution, dated September 28, 2013.
ISSUE:
Whether the notarization of documents by the secretary of respondent while he was out of
the country constituted negligence.
RULING:
The Court answers in the affirmative.
Respondent admitted in his comment and motion for reconsideration that the 18
documents were notarized under his notarial seal by his office secretary while he was out
of the country. This clearly constitutes negligence considering that respondent is
responsible for the acts of his secretary. Section 9 of the 2004 Rules on Notarial Practice
provides that a “Notary Public” refers to any person commissioned to perform official acts
under these Rules. A notary public’s secretary is obviously not commissioned to perform
the official acts of a notary public.
45
Respondent must fully bear the consequence of his negligence. A person who is
commissioned as a notary public takes full responsibility for all the entries in his notarial
register. He cannot relieve himself of this responsibility by passing the buck to his
secretary.
Respondent violated Canon 9 of the CPR which requires lawyers not to directly or
indirectly assist in the unauthorized practice of law. Due to his negligence that allowed
his secretary to sign on his behalf as notary public, he allowed an unauthorized person
to practice law. By leaving his office open despite his absence in the country and with
his secretary in charge, he virtually allowed his secretary to notarize documents without
any restraint.
Respondent also violated his obligation under Canon 7 of the CPR, which directs every
lawyer to uphold at all times the integrity and dignity of the legal profession. The
people, who came into his office while he was away, were clueless as to the illegality of
the activity being conducted therein. They expected that their documents would be
converted into public documents. Instead, they later found out that the notarization
of their documents was a mere sham and without any force and effect. By prejudicing
the persons whose documents were notarized by an unauthorized person, their
faith in the integrity and dignity of the legal profession was eroded.
46

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DANTE LA JIMENEZ & LAURO G. VIZCONDE, vs. ATTY. FELISBERTO L.

(AC 8108. July, 2014)

ISSUE: Whether or not Verano should be suspended for violating CPR.

By now, it is basic that there is neither a plaintiff nor a prosecutor in disciplinary

Hence, if the evidence on record warrants, the respondent may be suspended or

We believe that other provisions in the Code of Professional Responsibility likewise

ISSUE: Whether or not the recommendation by the IBP-BOG is proper.

A.C. No. 10573, January 13, 2015

Responsibility that forbade him from engaging in unlawful, dishonest, immoral or

ANTONINA S. SOSA v. ATTY. MANUEL V. MENDOZA A.C. No. 8776.

IBP FINDINGS & RECOMMENDATION:

1) WHETHER OR NOT ATTY. MENDOZA SHOULD BE HELD LIABLE?

'Any gross misconduct of a lawyer in his professional or in his private capacity is a

Gross misconduct is defined as "improper or wrong conduct, the transgression of some

Rule 1.01 of the Code of Professional Responsibility is emphatic: 'Ta] lawyer

It is undisputed that Atty. Mendoza obtained a loan in the amount of PS00,000.00. He

In disciplinary proceedings against lawyers, the only issue is whether the

A.C. No. 10952 | January 26, 2016

Despite his promises, Atty. Salvado failed to settle his obligations

The checks he issued were merely intended as security or evidence of investment.

Investigating Commissioner recommended that Atty. Salvado be meted a penalty of suspension

A.C. No. 10605, February 17, 2016

A.C. No. 9574, June 21, 2016

Canon 7 of the Code of Professional Responsibility specifically mandates all lawyers to

PEREZ VS. CATINDIG

A.C. No. 5816, March 10, 2015

RATIO:The Code of Professional Responsibility provides:chanRoblesvirtualLawlibrary

Contracting a marriage during the subsistence of a previous one amounts to a grossly

There is insufficient evidence to prove the affair between the respondents.

A.C. No. 10676, September 08, 2015

1. AAA, who is the spouse of a colleague in the UP College of Law, from

Should Atty. Pangalangan be disbarred?

Atty. Pangalangan was disbarred by the SC for grossly immoral conduct.

CANON 1 - A LAWYER SHALL UPHOLD THE CONSTITUTION, OBEY THE LAWS OF

CANON 7 - A LAWYER SHALL AT ALL TIMES UPHOLD THE INTEGRITY AND

In sum, Atty. Pangalangan displayed deplorable arrogance by making a mockery out of

PETITION FOR AUTHORITY TO CONTINUE USE OF THE FIRM NAME “SYCIP,

PETITION FOR AUTHORITY TO CONTINUE USE OF THE FIRM NAME “SYCIP,

Bumactao v Fano AC 10286

We are not impressed.

Legal Ethics, Deceitful Conduct of a Lawyer; Lawyer’s Signature on the Pleading

Samuel Arnado v Atty. Homobono A. Adaza

The OBC recommended that respondent be declared a delinquent member of

The Court DECLARED Atty. Homobono A. Adaza as a delinquent member of the

Catu vs. Rellosa [A.C. No. 5738. February 19, 2008]

Whether or not Atty. Rellosa violated the Code of Professional Responsibility.

YES. Respondent suspended for six (6) months.

HEINZ R. HECK v. JUDGE ANTHONY E. SANTOS

401 SCRA 46 (2003)

Whether or not Judge Santos is guilty of gross ignorance of the law

AREOLA vs. ATTY. MENDOZA A.C. No. 10135 January 15,

A.C. No. 11069, June 08, 2016

BUNAGAN-BANSIG vs. ATTY. CELERA A.C. No. 5581. January 14,

The Code of Professional Responsibility provides:

A.C. No. 8210, August 08, 2016

The Court's Ruling

WHEREFORE, respondent Arty. Ernesto V. Villagarcia is found GUILTY of violation of

JOSE C. SABERON v. ATTY. FERNANDO T. LARONG

561 SCRA 493 (2008)

Whether or not Larong is guilty of grave misconduct

A.C. No. 10303 April 22, 2015

JOY A. GIMENO, Complainant,

MAXIMINO NOBLE III, Complainant, v. ATTY. ORLANDO O. AILES, Respondent.

PERLAS-BERNABE, J. | A.C. No. 10628 | July 01, 2015