LEGAL ETHICS CASE DIGESTS

L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS CONTENTS
CANDOR AND FAIRNESS (CANON 10) .................................................................................. 1 KOMATSU INDUSTRIES (PHILS.) V. COURT OF APPEALS .............................................. 1 HEIRS OF HERMAN RAY ROMERO V. REYES .................................................................... 1 IN RE: 1989 ELECTION OF IBP ......................................................................................... 2 BERENGUE V. CARRANZA..................................................................................................... 6 MUOZ V. PEOPLE ................................................................................................................. 7 ARTIAGA, JR. V. VILLANUENA ............................................................................................. 8 OCCEA V. MARQUEZ .........................................................................................................10 QUASHA V. JUAN ..................................................................................................................11 SURIGAO V. CLORIBAL (MISSING) .................................................................................12 ADEZ REALTY, INC. V. COURT OF APPEALS ...................................................................12 SEEING THE JUDGE IN CHAMBERS (RULE 13.01) ...........................................................13 AUSTRIA V. MASAQUEL ......................................................................................................13 RESPECT TO COURT/DISCIPLINARY (CANON 11) AUTHORITY OF THE COURT .......15 ZALDIVAR V. GONZALES .....................................................................................................15 IN RE: PONCIANO B. JACINTO...........................................................................................16 IN RE: ALMACEN .................................................................................................................18 RHEEM OF THE PHILIPPINES V. FERRER ........................................................................20 MONTECILLO V. GICA..........................................................................................................21 BALAOING V. CALDERON....................................................................................................22 MACEDA V. ABIERRA ..........................................................................................................24
L E G AL E TH ICS C AS E D I GE ST S | BY: ALOJADO, ATIENZA, BALDERAMA, CAMARAO, CARANDANG, CRUZ, ESTILLES, GARCIA, GONZAGA, HUI, LAZARO, SENAJON | 2D 2015|
L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS
CANDOR AND FAIRNESS (CANON 10)

KOMATSU INDUSTRIES (PHILS.) V. COURT OF APPEALS
FACTS: National Investment and Development Corp. (NIDC) granted Komatsu Industries (Phils.), Inc. (KIPI) a direct loan of P8,000,000 and a P2,000,000 guarantee to secure PNB. As security thereof, a Deed of Real Estate Mortgage was executed by KIPI in favour of NIDC covering a parcel of land with all its improvements embraced in TCT No. 469737. KIPI then executed an Amendment of Mortgage Deed covering the same parcel of land regarding letters of credit by PNB in favour of KIPI with foreign suppliers worthUS$1,564,826. Upon full payment of KIPIs account with NIDC and the 2,000,000 credit line with PNB, NIDC executed a Deed of Release and Cancellation of Mortgage. By virtue of this release, NIDC returned the owners copy of the TCT to KIPI and registered the Deed of Release with the Registry of Deed. However, PNB requested the return of the TCT due to unsettled accounts based on the subsequent amendment of the mortgage. The return was made but after a year, PNB filed for extrajudicial foreclosure of the property. KIPI contests the foreclosure saying that the release by NIDC had the effect of releasing the real estate mortgage. ISSUE: W/N NIDCs Deed of Release is binding on PNB? HELD: NO. PNB was not a signatory to such agreement. It is a separate and distinct personality from NIDC. NIDC was in no position to state that Komatsus direct obligation PNB has been fully paid. (In relation to Legal Ethics):
The Court reprimanded KIPI for insinuating that Padilla Law Offices used the friendship and connection of retired Justice TeodoroPadilla with the ponente of the CA decision for disposing the case in their favour as a birthday and parting gift. When the said ponente declined and unloaded case, it was still allegedly raffled to another good friend of Justice Padilla. However, based on therecords, the case was directly raffled to the Second Division and there was no prior ponente to whom it was assigned.The Court said that it should prove its charges and refrain from conduct tending to create mistrust our judicial system throughinnuendos on which no evidence is offered or indicated to be proffered.
HEIRS OF HERMAN RAY ROMERO V. REYES

FACTS: 1. The Heirs of the late Herman Rey Romero (Heirs) were interveners in a civil case. The subject matter is a property subject of multiple sales, in fact, sold thrice over. It was concluded when the judge rendered the decision based on a compromise agreement. 2. Essentially, the compromise agreement ceded possession of the subject property to V.R. Gonzales Credit Enterprises Inc., (V.R.Credit ) in exchange for the Heirs and Elizabeth Reyes receiving certain sum of money. 3. Unfortunately, the building housing the branch of RTC Bulacan was gutted by fire. Thus, the case records were burned. The Heirs filed a motion for reconstitution of the records of the case. After it was granted, the copy of the compromise agreement was submitted, bearing only on the part of Reyes. 4. After 2 years, V.R. Credit has not complied its obligations with the complainants. They filed a motion for issuance of writ of execution. V.R. Credit moved to dismiss on the ground that it was premature and Veronica Gonzales did not sign the compromise agreement and has not been duly authorized to sign in behalf of V.R. Credit. 5. Due to this, RTC denied the motion for execution and declared the compromise agreement to be unenforceable. Thus, the
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BY: ALOJADO ASAMA ATIENZA BALDERAMA BRIONES CAMARAO CARANDANG CRUZ DUMA ESTILLES GARCIA GONZAGA LAZARO LIM LORENZO RELOJO SENAJON TONGSON TRONQUED |
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Heirs charged Atty. Venancio Reyes (counsel of V.R. Credit) of willful and intentional falsehood. Atty. Reyes denied the charge, stating that it was a valid defense in favor of his client. In addition, he cannot assert based on his personal knowledge that Gonzales actually signed the agreement. The IBP found Atty. Reyes guilty. ISSUE: WON Atty. Reyes is guilty for willful and intentional falsehood. RULING: 1. Yes, he is guilty. Lawyers are guardians of truth and rule of law. When they appear before a tribunal, they must act as officers of the court. In all their dealings, they may not resort to the use of deception. The Code of Professional Responsibility bars them from committing any falsehood or misleading the court. 2. Atty. Reyess contention that it was a valid defense in favor of his clients is untenable. Records show that Atty. Reyes participated in the negotiation of the Agreement. On several occasions, he vouched for its existence and validity. He used it as ag r o u n d t o s u p p o r t h i s m o t i o n t o dismiss the forcible entry case against his clients. W h e n t h e H e i r s s u b m i t t e d a c o p y o f t h e Agreement, he never raised any objection. His initial defense to the writ of execution was that it was premature, implying he acceded to the Agreement. 3. It was suspicious of him to raise the defense that Gonzales never signed the Agreement when he had no other recourse. Lawyers are obliged to protect their clients. However, their fidelity to their causes must always be within the parameters of the law. Atty. Reyes is suspended for 1 year from the practice of law.
IN RE: 1989 ELECTION OF IBP

Facts: (please bear with the long narration of facts, as this case is regarding an investigation of violations in the 1989 elections of the IBP) The IBP held their annual election at the PICC, electing, among other Atty. Violeta Drilon as IBP President (wife of then Labor Secretary Franklin Drilon, now Senator). The newly-elected officers were set to take the their oath of office on July 4,1989, before the Supreme Court en banc. However, disturbed by the widespread reports received by some members of the Court from lawyers who had witnessed or participated in the proceedings and the adverse comments published in the columns of some newspapers about the intensive electioneering and overspending by the candidates, led by the main protagonists for the office of president, namely, Attorneys Nereo Paculdo, Ramon Nisce, and Violeta C. Drilon, the alleged use of government planes, and the officious intervention of certain public officials to influence the voting, all of which were done in violation of the IBP By-Laws which prohibit such activities. The Supreme Court en banc, exercising its power of supervision over the Integrated Bar, resolved to suspend the oath-taking of the IBP officers-elect and to inquire into the veracity of the reports. Outcome of Investigation: Article I, Section 4 of the IBP By-Laws emphasizes the "strictly nonpolitical" character of the Integrated Bar of the Philippines, thus: "SEC. 4. Non-political Bar. The Integrated Bar is strictly non-political, and every activity tending to impair this basic feature is strictly prohibited and shall be penalized accordingly. No lawyer holding an elective, judicial, quasi-judicial, or prosecutory office in the Government or any political subdivision or instrumentality thereof shall be eligible for election or appointment to any position in the Integrated Bar or any
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Chapter thereof. A Delegate, Governor, officer or employee of the Integrated Bar, or an officer or employee of any Chapter thereof shall be considered ipso facto resigned from his position as of the moment he files his certificate of candidacy for any elective public office or accepts appointment to any judicial, quasi-judicial, or prosecutory office in the Government or any political subdivision or instrumentality thereof. "' Section 14 of the same By-Laws enumerates the prohibited acts relative to IBP elections: SEC. 14. Prohibited acts and practices relative to elections. The following acts and practices relative to election are prohibited, whether committed by a candidate for any elective office in the Integrated Bar or by any other member, directly or indirectly, in any form or manner, by himself or through another person: (a) Distribution, except on election day, of election campaign material; (b) Distribution, on election day, of election campaign material other than a statement of the biodata of a candidate on not more than one page of a legal-size sheet of paper; or causing distribution of such statement to be done by persons other than those authorized by the officer presiding at the elections; (c) Campaigning for or against any candidate, while holding an elective, judicial, quasi-judicial or prosecutory office in the Government or any political subdivision, agency or instrumentality thereof; (d) Formation of tickets, single slates, or combinations of candidates, as well as the advertisement thereof; (e) For the purpose of inducing or influencing a member to withhold his vote, or to vote for or against a candidate, (1) payment of the dues or other indebtedness of any member; (2) giving of food, drink, entertainment, transportation or any article of value, or any similar consideration to any person; or (3) making a promise or causing an expenditure to be made, offered or promised to any person." Section 12(d) of the By-Laws prescribes sanctions for violations of the above rules: (d) Any violation of the rules governing elections or commission of any of the prohibited acts and practices defined in Section 14 prohibited Acts and Practices relative to elections) of the by-laws of the Integrated Bar shall be a ground for the disqualification of a candidate or his removal from office if elected, without prejudice to the imposition of sanctions upon any erring member pursuant to the By-laws of the Integrated Bar. At the formal investigation which was conducted by the investigating committee, the following violations were established: (1) Prohibited campaigning and solicitation of votes by the candidates for president, executive vice-president, the officers of candidate the House of Delegates and Board of Governors - The three candidates for IBP President Drilon, Nisce and Paculdo began travelling around the country to solicit the votes of delegates as early as April 1989 (2) Use of PNB plane in the campaign Atty. Drilon admitted to having hitchhiked on the plane to assess their chances with the IBP Bicol region (3) Formation of tickets and single slates each candidate for president formed their own tickets
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(4) Giving free transportation to out-of-town delegates and alternates some delegates admitted to have had their plane tickets paid for them to attend the elections (5) Giving free hotel accommodations, food, drinks, entertainment to delegates the three candidates for president reserved hotels to accommodate the delegated: Atty. Drilon at Philippine Plaza; Atty. Nisce at Hyatt Hotel; Atty. Paculdo at Holiday Inn (6) Campaigning by labor officials for Atty. Violeta Drilon Franklin Drilon was then Labor Secretary and certain official of DOLE campaigned for Atty. Violeta (7) Paying the dues or other indebtedness of any number the IBP dues of the delegates were paid for them by the candidates (8) Distribution of materials other than bio-data of not more than one page of legal size sheet of paper print materials other than bio-data have been distributed during elections (9) Causing distribution of such statement to be done by persons other than those authorized by the officer presiding at the election uniformed girls have been employed by Atty. Nisce, and Atty. Violeta was helped by members of the Sigma Rho Fraternity (10) Inducing or influencing a member to withhold his vote, or to vote for or against a candidate some candidates were persuaded not to run or to changed tickets. Findings: The Investigation Committee concluded the investigation with the following: From all the foregoing, it is evident that the manner in which the principal candidates for the national positions in the Integrated Bar conducted their campaign preparatory to the elections on June 3, 1989, violated Section 14 of the IBP By-Laws and made a travesty of the idea of a "strictly non-political" Integrated Bar enshrined in Section 4 of the By-Laws. The setting up of campaign headquarters by the three principal candidates (Drilon, Nisce and Paculdo) in fivestar hotels: The Philippine Plaza, the Holiday Inn and The Hyatt the better for them to corral and entertain the delegates billeted therein; the island hopping to solicit the votes of the chapter presidents who comprise the 120-member House of Delegates that elects the national officers and regional governors; the formation of tickets, slates, or line-ups of candidates for the other elective positions aligned with, or supporting, either Drilon, Paculdo or Nisce; the procurement of written commitments and the distribution of nomination forms to be filled up by the delegates; the reservation of rooms for delegates in three big hotels, at the expense of the presidential candidates; the use of a PNB plane by Drilon and some members of her ticket to enable them to "assess their chances" among the chapter presidents in the Bicol provinces; the printing and distribution of tickets and bio-data of the candidates which in the case of Paculdo admittedly cost him some P15,000 to P20,000; the employment of uniformed girls (by Paculdo) and lawyers (by Drilon) to distribute their campaign materials on the convention floor on the day of the election; the giving of assistance by the Undersecretary of Labor to Mrs. Drilon and her group; the use of labor arbiters to meet delegates at the airport and escort them to the Philippine Plaza Hotel; the giving of pre-paid plane tickets and hotel accommodations to delegates (and some families who accompanied them) in exchange for their support; the pirating of some candidates by inducing them to "hop" or "flipflop" from one ticket to
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another for some rumored consideration; all these practices made a political circus of the proceedings and tainted the whole election process. The candidates and many of the participants in that election not only violated the By-Laws of the IBP but also the ethics of the legal profession which imposes on all lawyers, as a corollary of their obligation to obey and uphold the constitution and the laws, the duty to "promote respect for law and legal processes" and to abstain from 'activities aimed at defiance of the law or at lessening confidence in the legal system" (Rule 1.02, Canon 1, Code of Professional Responsibility). Respect for law is gravely eroded when lawyers themselves, who are supposed to be millions of the law, engage in unlawful practices and cavalierly brush aside the very rules that the IBP formulated for their observance. Conclusion: The Court annulled the 1989 Elections for being violative of the direct provisions of the By-laws of the IBP and disqualified all persons directly involved with the tainted elections from presenting themselves as candidate for any position, and made the following resolutions: It has been mentioned with no little insistence that the provision in the 1987 Constitution (See. 8, Art. VIII) providing for a Judicial and Bar Council composed of seven (7) members among whom is "a representative of the Integrated Bar," tasked to participate in the selection of nominees for appointment to vacant positions in the judiciary, may be the reason why the position of IBP president has attracted so much interest among the lawyers. The much coveted "power" erroneously perceived to be inherent in that office might have caused the corruption of the IBP elections. To impress upon the participants in that electoral exercise the seriousness of the misconduct which attended it and the stern disapproval with which it is viewed by this Court, and to restore the non-political character of the IBP and reduce, if not entirely eliminate, expensive electioneering for the top positions in the organization which, as the recently concluded elections revealed, spawned unethical practices which seriously diminished the stature of the IBP as an association of the practitioners of a noble and honored profession, the Court hereby ORDERS: 1. The IBP elections held on June3,1989 should be as they are hereby annulled. 2. xxx
3. The former system of having the IBP President and Executive Vice-President elected by the Board of Governors (composed of the governors of the nine [91 IBP regions) from among themselves (as provided in Sec. 47, Art. VII, Original IBP By-Laws) should be restored. The right of automatic succession by the Executive VicePresident to the presidency upon the expiration of their two-year term (which was abolished by this Court's resolution dated July 9,1985 in Bar Matter No. 287) should be as it is hereby restored. xxx 12. Special elections for the Board of Governors shall be held in the nine (9) IBP regions within three (3) months, after the promulgation of the Court's resolution in this case. Within thirty (30) days thereafter, the Board of Governors shall meet at the IBP Central Office in Manila to elect from among themselves the IBP national president and executive vice-president. In these special elections, the candidates in the election of the national officers held on June 3,1989, particularly identified in Sub-Head 3 of this Resolution entitled "Formation of
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Tickets and Single Slates," as well as those identified in this Resolution as connected with any of the irregularities attendant upon that election, are ineligible and may not present themselves as candidate for any position. prolongation of the cadastral suit for presenting evidence therein containing a false statement inconsistent with facts he definitely knows by reason of the family litigations between his client and complainant herein, which are rooted in successional rights [and that] respondent's failure to discharge his duties as a lawyer consistent with his oath of office finds sanction in Rule 138, Section 27, Revised Rules of Court." ISSUE vs. PEDRO B. CARRANZA, WON the finding that there was nothing willful in introducing false evidence before the court, thereby defeating the charge of deliberate deception, would by itself exculpate Atty. Caranza from any responsibility RULING NO. Atty. Caranza is reprimanded and warned that a repetition of an offense of this character will be much more severely dealt with. Under the circumstances, it would be to err on the side of undue leniency if Atty. Caranza would be held blameless. He had incurred liability. His fidelity to his oath as attorney was less than entire. Every member of the bar must be on his guard, lest through oversight or inadvertence, the way he conducts his case or the evidence he presents could conceivably result in a failure of justice. Time and time again, lawyers have been admonished to remember that they are officers of the court, and that while they owe their clients the duty of complete fidelity and the utmost diligence, they are likewise held to strict accountability insofar as candor and honesty towards the court is concerned. Even if there be no intent to deceive, therefore, a lawyer whose conduct, as in this case, betrays inattention or carelessness should not be allowed to free himself from a charge thereafter instituted against him
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BERENGUE V. CARRANZA
EDUARDO J. BERENGUER, complainant, respondent. A.C. No. 716 FACTS Atty. Caranza was counsel who appeared for a client before a cadastral proceeding in Sorsogon. A complaint was filed against Atty. Caranza accusing him of knowingly introducing into evidence an Affidavit of Adjudication and Transfer executed by the mother of his client to the effect that her own mother (the grandmother) left no legitimate ascendants or descendants or any other heirs except herself, when, as a matter of fact, the deceased was survived by four other daughters and one son, father of the complainant thereby doing falsehood in court. In his defense, he claims that he had no hand in the preparing the affidavit introduced in the cadastral proceeding and he only introduced the same in evidence to prove the fact of transfer. Atty. Caranza also admitted that he was not very meticulous about the affidavit. The Solicitor General argues that while Atty. Caranza may not have willfully introduced a false statement in court, the latter could not be totally excused from liability for failing to properly inform himself of the evidence in court. Accordingly he charges the lawyer with charged with "violation of his oath of office, [having] caused confusion and January 30, 1969
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by the mere plea that his conduct was not wilful and that he has not consented to the doing of the falsity. A lawyer's oath is one impressed with the utmost seriousness; it must not be taken lightly. Every lawyer must do his best to live up to it. There would be a failure of justice if courts cannot rely on the submission as well as the representations made by lawyers, insofar as the presentation of evidence, whether oral or documentary, is concerned. If, as unfortunately happened in this case, even without any intent on the part of a member of the bar to mislead the court, such deplorable event did occur, he must not be allowed to escape the responsibility that justly attaches to a conduct far from impeccable In the case Vicente Muoz v. People of the Philippines and the Court of Appeals where the main issue was whether petitioner Muoz is guilty of homicide through reckless negligence in a boat collision incident, CA found conflicting versions of the case. It being conceded that the two versions recounted above are by themselves credible, although they are conflicting the same cannot be binding on, and is therefore, reviewable by the Honorable Supreme Court. In a pleading (joint apology) by Ordonez and sutton, which sought to make amends, it was explained that Sutton had no intention to misrepresent any question of fact before this Honorable Court for her personal gain or benefit, and that it was her lack of adequate extensive experience in preparing petitions for certiorari which may have caused the inaccurate statements in the said petition which were enumerated in the order of this Honorable Court; that Sutton contritely realizes the errors which she committed in the preparation of the said petition for certiorari and that the same will not recur in the future as she will always abide by the provisions on candor and fairness in the Canons of Professional Ethics, which reads: "22. [Candor and Fairness]. The conduct of the lawyer before the court and with other lawyers should be characterized by candor and fairness. It is not candid or fair for the lawyer knowingly to misquote the contents of a paper, the testimony of a witness, the language or the argument of opposing counsel, or the language of a decision or a textbook or; with knowledge of its invalidity, to cite as authority a decision that has been overruled, or a statute that has been repealed; or in argument to assert as fact that which has not been proved, or in those jurisdictions where a side has the opening and closing arguments to mislead his opponent by concealing or withholding positions in his opening argument upon which his side then intends to rely. ..." Issue: Whether or not Suttons contentions makes the misconduct excusable. Held:
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MUOZ V. PEOPLE
VICENTE MUOZ, petitioner, vs. PEOPLE OF THE PHILIPPINES and THE COURT OF APPEALS, respondents, DELIA T. SUTTON,respondent. Facts: Respondent Delia T. Sutton was a member of the Philippine Bar and connected with the law firm of Salonga, Ordoez, Yap, Parlade, and Associates. In a petition for certiorari prepared by her to review a Court of Appeals decision, she attributed to it a finding of facts in reckless disregard of what in truth was its version as to what transpired (the petition makes reference to "findings" of the Court of Appeals which is not true; refers to a portion of the same quotation, as "the established uncontroverted facts recognized by the Court of Appeals," which is, likewise, untrue). When given an opportunity to make proper amends, both in her appearance before us and thereafter in her memorandum, there was lacking any showing of regret for such misconduct. Background:
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NO. Ratio: The Court found that the "Joint Apology" thus offered did mitigate to some extent the liability of respondent Sutton. Some members of the Court feel, however, that it does not go far enough. While expressing regret and offering apology, there was lacking that free admission that what was done by her should not characterized merely as "errors" consisting as they do of "inaccurate statements." If there were a greater sincerity on her part, the offense should have been acknowledged as the submission of deliberate misstatements. There ought to be, for the apology to gain significance, no further attempt at minimizing the enormity of the misdeed. Even with due recognition then that counsel is expected to display the utmost zeal in defense of a client's cause, it must never be at the expense of deviation from the truth. As set forth in the applicable Canon of Legal Ethics: "Nothing operates more certainly to create or to foster popular prejudice against lawyers as a class, and to deprive the profession of that full measure of public esteem and confidence which belongs to the proper discharge of its duties than does the false claim, often set up by the unscrupulous in defense of questionable transactions, that it is the duty of the lawyer to do whatever mayenable him to succeed in winning his client's cause." What is more, the obligation to the bench, especially to this Court, for candor and honesty takes precedence. It is by virtue of such considerations that punishment that must fit the offense has to be meted out to respondent Delia T. Sutton. ATTY. LUIS V. ARTIAGA vs. ATTY. ENRIQUE C. VILLANUEVA, respondent. JR., complainant,
The properties involved here are three parcels of land in Los Banos, Laguna. Estolano was able to acquire an Original title to the first parcel of land. The second and third parcels were the object of Revocable Permit Applications filed by Malabayabas and Suyo. 3 months after the filing, Canuto transferred his right over the third parcel to Estolano. Later on, Malabayabas also sold his rights over the second parcel to Estolano. Estolano filed Insular Government Property Sales Application (New) covering the second and third parcels. Aquino filed his Revocable Permit Application over an area of 8,000 sq.m, which was later found to cover a part of the first parcel already titled in favor of Estolano and of the third parcel transferred to him by Suyo. Guanzon, Aquino's sister-in-law, also filed Revocable Permit Application over the second parcel. Eventually, the conflicts were taken cognizance of by the Bureau of Lands, and ruled in favor of Estolano. Aquino and Guanzon moved for the reconsideration of the decision, and the Director of Lands, amended his previous Decision and awarding to Aquino preferential right to that area actually occupied and cultivated by him. Estolano, Aquino and Guanzon appealed to the Secretary of Agriculture and Natural Resources who affirmed the first decision of the Bureau of Lands (in favor of Estolano only). Guanzon moved for the reconsideration of the Secretary's Decision but said Motion was denied. Aquino appealed the Decision of the Secretary to the Office of the President of the Philippines, which likewise affirmed the Decision appealed from. The Decision of the Director of Lands having become final, an order of Execution thereof was issued. However, Aquino and Guanzon remained in possession of the subject property. Estolano then filed the ejectment
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ARTIAGA, JR. V. VILLANUENA

A.M. No. 1892 July 29, 1988
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case in the lower court which eventually gave rise to the proceedings now challenged in this petition. Several cases were filed by Aquino and Guanzon (through their counsel), all of which were dismissed complaint for forcible entry against Estolano in the MTC annulment of Estolano's title over the same land with the CFI entry case must be filed within one year from the accrual of the cause of action under Rule 70, Section 1. Such action of Atty. Villanueva counsel is a clear violation of his oath that "he will do no falsehood nor consent to the doing of any in court." A legal counsel is of course expected to defend his client's cause with zeal, but not at the disregard of the truth. The duty of an attorney to the courts to employ, for the purpose of maintaining the causes confided to him, such means as are consistent with truth and honor cannot be overemphasized. His high vocation is to correctly inform the court upon the law and the facts of the case, and to aid it in doing justice and arriving at correct conclusions. He violated his oath of office when he resorted to deception. Worse, he had caused his client to perjure himself thus subjecting the latter to criminal prosecution for perjury brought before the Municipal Court of Los Banos, Laguna. Instead of safeguarding the interests of his client as his responsibility dictates, he did exactly the opposite by causing his client to commit a felony. From the foregoing, the lack of candor of Atty. Villanueva counsel towards the court is evident. This lack of candor and honesty to the courts and his adversary is further demonstrated by other acts of respondent. The other actions of Atty. Villanueva likewise show his lack of candor towards the court: Non-appearance during the hearing for the motion filed by Estolano, asking that the Provincial Sheriff be authorized to forcibly evict Atty. Villanuevas clients. (Atty Villanueva instead filed an "Opposition/ Manifestation" informing the court of a petition for certiorari filed against the presiding judge filing another case, this time for annulment of the title (dismissed on the ground of res judicata and prescription, but still appealed by Atty. Villanueva to the CA) filing of another case before the Court of Agrarian Relations and not disclosing prior law suits and decisions rendered relative to the subject land
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They also filed a complaint with the Court of Agrarian Relations (CAR) at San Pablo City and the CAR issued an order requiring Estolano to respect Aquino's possession. Atty. Luis V. Artiaga Jr. then sought the disbarment of Atty. Enrique C. Villanueva for alleged unethical practices. 1. That Atty. Villanueva had caused his client to perjure himself; 2. That he lacks candor and respect toward his adversary and the courts; and 3. That he had been abusive of the right of recourse to the courts. W/N Atty. Villanueva is guilty of the alleged unethical practices. HELD: Yes. We find Atty. Villanueva Atty. Villanueva guilty as above charged. RATIO: The complaint for forcible entry filed by Villanuevas client are clear proofs that Atty. Villanueva had indeed caused his client Aquino to perjure himself as to the date he lost possession of the subject property so as to place the case within the jurisdiction of the court. In the original complaint, Atty. Villanuevas client alleged that he was dispossessed of the subject land in 1960, while in the amended complaint, he alleged it was in June, 1973. Clearly, this was a ploy concocted by Atty. Villanueva to enable the court to acquire jurisdiction over the case since a forcible
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Atty. Villanueva resorted to forum shopping, continuously seeking the court where he may possibly obtain favorable judgment, thereby adding to the already clogged dockets of the courts with the unmeritorious cases he filed. He grossly abused his right of recourse to the courts by filing multiple petitions or complaints for a cause that had been previously rejected in the false hope of getting some favorable action, somehow, thus, obstructing the administration of justice. He was derelict in his duty as counsel to maintain such actions or proceedings only as appears to him to be just, and such defenses only as he believes to be honestly debatable under the law. He had thus prostituted his office at the expense of justice. The practice of law is a privilege accorded only to those who measure up to certain standards of mental and moral fitness. For a counsel who has been sworn to assist in the administration of justice and to uphold the rule of law, Atty. Villanueva has miserably failed to live up to the standards expected of a member of the Bar. Instead of assisting in the speedy disposition of cases, he made a mockery of our system of justice, thus deserving to be censured and penalized by this Court. No doubt, Atty. Villanueva is guilty of gross misconduct in office. Petitioners filed a Motion for Partial Payment of Attorneys' Fees, dated November 18, 1965, asking the court to approve payment to them of P30,000.00, as part payment of their fees for their services as counsel for the executrix since 1963. Lily Ogan Peralta, William Ogan, Jr. and Ruth Ogan, moved to defer consideration of the motion until after the total amounts for the executrix's fees and the attorney's fees of her counsel shall have been agreed upon by all the heirs. In July, 1966, five of the seven instituted heirs, namely, Lily Ogan Peralta, Necitas Ogan Occena, Federico M. Ogan, Liboria Ogan Garcia and Nancy Ogan Gibson, filed with the court a Manifestation stating that they had no objection to the release of P30,000.00 to petitioners as partial payment of attorney's fees and recommending approval of petitioners' motion. Respondent Judge issued an order fixing the total fees of petitioners for the period March, 1963 to December, 1965 at P20,000.00. Petitioners moved to reconsider that order. On January 12, 1967, respondent issued an order not only denying petitioners' Motion for Reconsideration but also modifying the original order by fixing petitioners' fees for the entire testate proceedings at P20,000. Petitioners contend that respondent Judge acted with grave abuse of discretion or in excess of jurisdiction in fixing the entire attorney's fees to which they are entitled as counsel for the executrix, and in fixing the said fees in the amount of P20,000.00 Also, petitioners have filed petitions for indirect contempt of court against intervenor I. V. Binamira charging the latter of having made false averments in this Court. Issue: Whether or not Binamira is liable. Held:
OCCEA V. MARQUEZ
Facts: Petitioners, Atty. Jesus V. Occea and Atty. Samuel C. Occea, are the lawyers for the estate executrix, Mrs. Necitas Ogan Occea, and they had been representing the said executrix since 1963, defending the estate against claims and protecting the interests of the estate. In order to expedite the settlement of their deceased father's estate, the seven instituted heirs decided to enter into compromise with the claimants, as a result of which the total amount of P220,000.00 in cash was awarded to the claimants, including co-executor Atty. Isabelo V. Binamira, his lawyers and his wife. A partial distribution of the corpus and income of the estate was made to the heirs in the total amount of P450,000.00. On November 18, 1966, the estate and inheritance taxes were completely settled by the executrix.
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The rule is that when a lawyer has rendered legal services to the executor or administrator to assist him in the execution of his trust, his attorney's fees may be allowed as expenses of administration. The estate is, however, not directly liable for his fees, the liability for paymentmm resting primarily on the executor or administrator. If the administrator had paid the fees, he would be entitled to reimbursement from the estate. In fixing petitioners' attorney's fees solely on the basis of the records of the case, without allowing petitioners to adduce evidence to prove what is the proper amount of attorney's fees to which they are entitled for their entire legal services to the estate, respondent Judge committed a grave abuse of discretion correctable by certiorari. Evidently, such fees could not be adequately fixed on the basis of the record alone, considering that there are other factors necessary in assessing the fee of a lawyer, such as: (1) the amount and character of the services rendered; (2) the labor, time and trouble involved; (3) the nature and importance of the litigation or business in which the services were rendered; (4) the responsibility imposed; (5) the amount of money or the value of the property affected by the controversy or involved in the employment; (6) the skill and experience called for in the performance of the services; (7) the professional character and social standing of the attorney; and (8) the results secured, it being a recognized rule that an attorney may properly charge a much larger fee when it is contingent than when it is not. As stated above, petitioners have filed petitions for indirect contempt of court against intervenor I.V. Binamira charging the latter of having made f alse averments in this Court. We find no rule of law or of ethics which would justify the conduct of a lawyer in any case, whether civil or criminal, in endeavoring by dishonest means to mislead the court, even if to do so might work to the advantage of his client. The conduct of the lawyer before the court and with other lawyers should be characterized by candor and fairness. It is neither candid nor fair for a lawyer to knowingly make false allegations in a judicial pleading or to misquote the contents of a document, the testimony of a witness, the argument of opposing counsel or the contents of a decision. Before his admission to the practice of law, he took the solemn oath that he will do no falsehood nor consent to the doing of any in court, nor wittingly or willingly promote or sue any false, groundless or unlawful suit, and conduct himself as a lawyer with all good fidelity to courts as well as to his clients. We find that Atty. Binamira, in having deliberately made these false -allegations in his pleadings, has been recreant to his oath.
QUASHA V. JUAN
FACTS: A sea vessel, MV San Vicente - registered in the Philippines, was chartered by foreigners and foreign companies to deliver cargo from Sweden to Jeddah, Saudi Arabia. The payment scheme was supposed to be by time charter. Payment would have been in the amount of US $ 3,200 a day. However, after two months, the foreigners failed to pay the daily hire. It had docked in Jeddah but did not unload its cargo due to the fact of non-payment. Filipinas Carriers (FILCAR) exercised its lien over the goods transported as per the Charter Party (their contract). FILCAR asked to court for sale of the goods in the ship to satisfy the debt of the foreign companies to them. Later, the law firm of Quasha Asperilla Ancheta Valmonte Pea & Marcos intervened in the case on behalf of the agent of some of the foreign companies/defendants of the case. The agents name was Ahmed Baroom and he was supposedly the agent of AB Charles Thorburn & Co. and some companies in Saudi Arabia. Later, Baroom withdrew from pursuing the case but he failed to pay his lawyers (Quasha). The law firm of Quasha then filed a writ of preliminary attachment in a different CFI (Pasig the original case was in the CFI of Manila) claiming that it has a right to a portion of the goods as payment for its attorneys fees. The goods however have already been sold by the respondent court, the law firm now goes after the proceeds of the sale.
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the factual findings of CA with the apparent purpose of misleading this Court in order to obtain a favorable judgment. Consequently, Atty. Dacanay was disbarred from practicing law. Atty. Dacanay filed a Motion for Reconsideration and Leave to Offer Evidence Re Charge of Unauthorized Intercalation in a Judicial Record claiming that the inserted words were written by his client, the President of Adez Realty, Inc., and unwittingly adopted by his secretary. He manifested that he would not risk committing this act considering that he was a nominee for appointment as regional trial judge. However, this motion was denied by this Court. Subsequently, he filed a Motion to Lift (Disbarment) stating that he was already 62 years old, has learned his lesson from his mistake, was terribly sorry for what he had done, and in all candor promised that if given another chance he would live up to the exacting demands of the legal profession. He also appended several certifications of good moral character. This was again denied by the Court. Atty. Dacanay filed again an Ex-Parte Motion to Lift Disbarment admitting "with profound regret and with utmost humility his commission of an unpardonable mistake and ask(ed) that he be given another chance". His wife also wrote to the Court her fervent wish to take a second look into this matter as the entire family had been traumatized by the disbarment. Atty. Dacanay sent three more letters to the Court humbly asking for reconsideration and admitting full responsibility for the offense of intercalation. ISSUE/S: WON Atty. Dacanay should be allowed to resume to practice law RULING:
ISSUE: W/N Quasha is entitled to a portion of the goods or its proceeds?
RULING: No. The law firm should have pursued its claim to attorneys fees in the same court as an intervention petition for recovery of attorneys fees. The respondent CFI of Manila had already acquired jurisdiction over the goods as the case pending with it was already deciding upon the question of who the real owner of the cargo was. In filing with another CFI, multiplicity of suits occurred. The charging lien filed in Pasig was erroneous, an intervention petition for recovery of attorneys fees in the CFI of Manila was the proper action that should have been taken. This negligence by the law firm entitles it to no relief, the instant petition must be dismissed. Besides the goods have already been sold and delivered to a foreign buyer, the court has lost jurisdiction over it. Everything is already fait accompli (already done and beyond alteration).
SURIGAO V. CLORIBAL (MISSING) ADEZ REALTY, INC. V. COURT OF APPEALS

G.R. No. 100643 December 12, 1995 ADEZ REALTY, INCORPORATED, petitioner, vs. HONORABLE COURT OF APPEALS, THE PRESIDING JUDGE, REGIONAL TRIAL COURT, Br. 79, Morong Rizal, THE REGISTER OF DEEDS FOR QUEZON CITY, and AGUEDO EUGENIO, respondents. FACTS: Atty. Benjamin Dacanay (Atty. Dacanay) was found guilty by the Court guilty of intercalating a material fact in a decision of CA, thereby altering
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Yes, the disbarment of Atty. Dacanay is lifted and he is therefore allowed to resume the practice of law upon payment of the required legal fees. RATIO: The disbarment of Atty. Dacanay for three years has, quite apparently, given him sufficient time and occasion to soul-search and reflect on his professional conduct, redeem himself and prove once more that he is worthy to practice law and be capable of upholding the dignity of the legal profession. His admission of guilt and repeated pleas for compassion and reinstatement show that he is ready once more to meet the exacting standards the legal profession demands from its practitioners. counsel for Bravo. Bravo, through Atty. Sicat, filed a supersedeas bond to stay the execution of the judgment, Judge granted the stay of execution, over the objection of plaintiffs, and ordered the sheriff to restore the possession of the lands in San Carlos to Bravo. Austria likewise had asked for the appointment of a receiver over Bayambang land, which prayer was granted by Judge; but upon the filing of a bond by Bravo for the non-appointment of a receiver, the order receivership was set aside. Pending the approval of Bravos amended record on appeal, Atty. Sicat filed a motion for new trial and to set aside the judgment and, over the vigorous objection of Austria and company, the Judge granted the said motion. Before the opening of the court's session, Atty. Daniel Macaraeg, counsel for Austria and his co-plaintiffs, saw Judge in his chamber and verbally transmitted to him the request of petitioner that the Judge inhibit himself upon the ground that the new counsel Sikat, was his former associate. The Judge, rejected the request because, according to him, the reason for the request of his inhibition is not one of the grounds for disqualification of a judge. When the case was called for hearing in open court, the following transpired. Basically, the Judge asked if the petitioner doubted his integrity and Austria said yes. Heres the transcript for clarity: COURT: Atty. Macaraeg approached me in chambers requesting me to disqualify myself in hearing this case. Did you authorize Atty. Macaraeg to approach me verbally to disqualify myself from hearing this case because the lawyer of the other party was my former assistant? DOMINGO AUSTRIA: Yes, sir. COURT: Is that your reason why you requested Atty. Macaraeg to approach me, requesting me to disqualify myself simply because the lawyer of the other party was my assistant? DOMINGO AUSTRIA: Yes, sir.
SEEING THE JUDGE IN CHAMBERS (RULE 13.01)

AUSTRIA V. MASAQUEL
G.R. No. L-22536 August 31, 1967
DOMINGO V. AUSTRIA, petitioner, HON. ANTONIO C. MASAQUEL, in his capacity as the Presiding Judge of Branch II of the Court of First Instance of Pangasinan, respondent. FACTS Austria was one of the plaintiffs in a Civil Case against Bravo. Judge rendered a decision declaring the plaintiffs the owners of the 3 parcels of land in question and ordering Bravo to vacate the lands and pay Austria and company damages only with respect to the land located at Bayambang. The plaintiffs filed a motion for the immediate execution of the judgment which motion was granted and, upon the plaintiffs' having posted a surety bond in the sum of P2K, the sheriff placed them in possession of the lands in San Carlos. Atty. Mariano C. Sicat, a former assistant or associate of the Judge entered his appearance as the new
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COURT: All right. Do you doubt the integrity of the presiding Judge to decide this case fairly and impartially because the lawyer of the other party was my former assistant? Do you doubt? Just answer the question? DOMINGO AUSTRIA: Yes, sir. COURT: The Court hereby finds you guilty of contempt of Court and you are hereby ordered to pay a fine of P50.00. ATTY. MACARAEG: With due indulgence of this Honorable Court I have learned, after I have conferred with you in chambers, another ground of the plaintiffs for their requesting me to ask for the disqualification of Your Honor in this case, and this ground consists of the rampant rumor coming from the defendant Pedro Bravo himself that he is boasting in San Carlos that because he has a new lawyer, that surely he is going to win this case. COURT: Why did you not wait until the case is finally decided and find out if that is true or not? ATTY. MACARAEG: And maybe, that is why the plaintiffs requested me to approach Your Honor because of that rampant rumor that Pedro Bravo is spreading. COURT: Your client expressed openly in Court his doubts on the integrity of the Court simply based on rumors and that is a ground for contempt of court, if only to maintain the faith of the people in the courts. ATTY. MACARAEG: Taking into consideration that these plaintiffs are laymen and we cannot expect from them the thinking of a lawyer, I am most respectfully praying that the Order of this Court be reconsidered. COURT: Denied. Your client should pay a fine of P50.00. We will hear this case this afternoon. Austria, accordingly, paid the fine of P50.00 under protest. Having been punished summarily for direct contempt of court, and the remedy of Was Austria guilty of contempt? HELD No. RATIO We need to determine whether or not the petitioner was guilty of misbehavior in the presence of or so near a court or judge, as to obstruct or interrupt the proceedings before the same, or had committed an act of disrespect toward the court or judge. The respondent Judge considered the actuation of the petitioner, in the premises, as offensive, insulting, and a reflection on his integrity and honesty and a showing of lack of respect to the court. The Judge considered that Austria was not justified and had no reason to entertain doubts in his fairness and integrity simply because the defendant's counsel was his former associate.1wph1. When Austria requested the Judge to inhibit himself from further trying the case upon the ground that the counsel for the opposite party was the former associate of the respondent Judge, petitioner did so because he was impelled by a justifiable apprehension which can occur in the mind of a litigant who sees what seems to be an advantage on the part of his adversary; and that the petitioner made his request in a manner that was not disrespectful, much less insulting or offensive to the respondent Judge or to the court. While it is true that the Judge may not be compelled to disqualify himself, the fact that Atty. Sicat, admittedly his former associate, was counsel for a party in the case being tried by him, may constitute a just
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appeal not being available to him, petitioner filed the instant petition for certiorari before this Court. ISSUE
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or valid reason for him to voluntarily inhibit himself from hearing the case on a retrial, if he so decides, pursuant to the provision of the second paragraph of Section 1 of the said Rule 137.5 The apprehension of petitioner regarding the probable bias of respondent Judge does not appear to be groundless or entirely devoid of reason. The respondent Judge had decided the case in favor of petitioner and his co-plaintiffs, and that upon plaintiffs' timely motion and filing of bond they were already placed in possession of the lands in question pending appeal. It was when Atty. Sicat took over as new counsel for defendant that the latter was given back the properties, upon a motion to stay the execution of the judgment which was filed by said counsel and was granted by respondent Judge over the opposition of petitioner's counsel. Again, when the same counsel for defendant filed a motion for a new trial, said motion was granted by respondent Judge in spite of the vigorous objection of counsel for the petitioner and his co-plaintiffs. And then the petitioner became aware of the fact that his adversary, the defendant Pedro Bravo, had been boasting in San Carlos that he was sure to win his case because of his new lawyer. Austria the layman that he is did not take a belligerent or arrogant attitude toward respondent Judge. What he did was to request his lawyer, Atty. Macaraeg, to approach respondent Judge in his chamber and suggest to him to refrain from hearing the case on the new trial, precisely in order that the Judge might not be embarrassed or exposed to public odium. filed with the SC a petition for Certiorari, Prohibition and Mandamus assailing the authority of the Tanodbayan to investigate graft cases under the 1987 Constitution. The Court ruled that since the adoption of 1987 Constitution, respondents power as tanodbayan have been superseded by the creation of the Office of the Ombudsman, and that he becomes a Special Prosecutor of the State, the investigating power of which is dependent upon the authorization by the Ombudsman. The SC issued a Cease and Desist Order against Gonzalez directing him to temporarily restrain from investigating and filing informations against Zaldivar. Gonzalez filed an MR where he included statements which were unrelated in the issue raised in the Court like (a) that he had been approached twice by a leading member of the court and he was asked to go slow on Zaldivar and not to be too hard on him; (b) that he was approached and asked to refrain from investigating the COA report on illegal disbursements in the SC because it will embarrass the court; (c) that in several instances, the respondent was called over the phony by a leading member of the Court and was asked to dismiss the cases against two Members of the Court. Gonzalez however proceeded with the investigation and he filed criminal informations against Zaldivar and said in a newspaper interview that the SCs issuance of TRO is a manifestation that rich and influential persons get favorable actions from the SC, while it is difficult for an ordinary litigant to get his petition to be given due course. Zaldivar then filed a Motion for Contempt against Gonzalez. The SC then ordered Gonzalez to explain his side. Gonzalez insisted that the statements in the newspapers were true; that he was only exercising his freedom of speech; that he is entitled to criticize the rulings of the court. Respondent then sought to get some members of the Court to inhibit themselves in the resolution of the Zaldivar case for alleged bias and prejudice against him. Subsequently, he asked the whole Court to inhibit itself from passing upon the issue involved in proceeding and to pass on responsibility for this matter to the IBP, upon the ground that respondent cannot expect due process from this Court. The Court found respondent guilty of contempt of court and indefinitely suspended from the practice of law. He is assailing the said conviction and primarily raises his freedom of speech as a defense.
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RESPECT TO COURT/DISCIPLINARY (CANON 11) AUTHORITY OF THE COURT

ZALDIVAR V. GONZALES
Facts: Zaldivar was the governor of Antique who was charged before the Sandiganbayan for violations of the Anti-Graft and Corrupt Practices Act. Gonzalez, as the Tanodbayan, was investigating the case. Zaldivar then
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Issue: Whether or not Gonzalez is guilty of contempt Held: Yes. The Court concludes that respondent Gonzalez is guilty both of contempt of court in facie curiae and of gross misconduct as an officer of the court and member of the Bar. Gonzalez is suspended indefinitely from the practice of law. Ratio: -The statements of Gonzalez necessarily imply that the justices of the SC betrayed their oath of office. Those statements constitute the grossest kind of disrespect for the SC as they clearly debase and degrade the judicial system. The lawyers duty to render respectful subordination to the courts is essential to the orderly administration of justice. -Freedom of speech and of expression, like all constitutional freedoms, is not absolute and that freedom of expression needs on occasion to be adjusted to and accommodated with the requirements of equally important public interests. -Gonzalez is also entitled to criticize the rulings of the court but it is the cardinal of all such criticism that it shall be bona fide and shall not spill over the walls of decency and propriety. Intemperate and unfair criticism is a gross violation of the duty of respect to courts. It is such a misconduct that subjects a lawyer to disciplinary action. In this case, the statements of Gonzalez particularly the one where he alleged that members of the SC approached him, are of no relation to the Zaldivar case. Gonzalez are of such nature and were made in such a manner and under such circumstances, as to transcend the permissible limits of free speech. What is here at stake is the authority of the SC to confront and prevent a substantive evil consisting not only of the obstruction of a free and fair hearing of a particular case but also the avoidance of the broader evil of the degradation of the judicial system of a country and the destruction of the standards of professional conduct required from members of the bar and officers of the courts, which has some implications to the society.
IN RE: PONCIANO B. JACINTO

IN THE MATTER OF PROCEEDINGS FOR DISCIPLINARY ACTION AGAINST ATTY. PONCIANO B. JACINTO IN G.R. NO. 78926, ENTITLED "FACUNDA PALMARIO, vs. SOCIAL SECURITY SYSTEM, ET AL. FACTS: The client of Atty Ponciano Jacinto, Facunda Palmario was transferred from her position as acting section chief of the accounting department of the Social Security System to the real estate department as loans examiner. Claiming "mental torture" over her alleged demotion, she left the office and did not report back for more than a year and, when required to explain her absence within 72 hours, failed to do so. As a result, she was ordered dismissed as of her last day of actual service. She appealed her dismissal to the Civil Service Commissioner which, after hearing, modified the decision of the Social Security System and considered her not dismissed but merely resigned. Both the Social Security System and Facunda moved for reconsideration, but their motions were denied, prompting Facunda to come to the Supreme Court and her petition was dismissed. The merits of the abovementioned case are clear enough and do not need to be reviewed. But what has seriously concerned the Court is the arrogant manner and language of Facunda's counsel (Atty Jacinto) who, while professing respect for it, has made the following questionable
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-Under either the clear and present danger test or the balancing-ofinterest, the Court held that the statements made by respondent
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statements in order to persuade the Supreme Court to review and reverse its decision: SPECIAL AND VERY URGENT MANIFESTATION 1. To Alert the Hon. Court on Looming Danger, and 2. To Avert That Danger Before It Happens. xxx xxx xxx 10. So, with this MANIFESTATION, we, as Member of the Bar and Officer of the Hon. Court, are only doing our duty in ALERTING the Hon. Court of a LOOMING DANGER AHEAD, that, should it continue to disregard its record and the laws involved in this case, resulting in a miscarriage of justice, a Paradox of Paradoxes and an Irony of Ironies would result, i.e., a hypothetical Supreme Court that were better if inexistent because then it could do no harm. xxx xxx xxx FINAL PLEA FOR THE INTEGRITY OF THE HONORABLE SUPREME COURT xxx xxx xxx 1. Heretofore this Hon. Court has consistently and erroneously made dismissal and denial resolutions of petitioner's bid for reinstatement, IN COMPLETE DISREGARD OF THE LEGAL BASES REPETITIOUSLY CITED in all pleadings on her behalf. xxx xxx xxx 4. THE INTEGRITY OF THE HON. SUPREME COURT BEING IN JEOPARDY IF IT DOES NOT CHANGE ITS COURSE, GO INTO THIS CASE PERSONALLY AND IN DEPTH, AND AGAIN DENY PALMARIO'S LAST PLEA FOR JUSTICE, it is our duty to call the attention of the Hon. Court to what then would happen: One: The Hon. Supreme Court being composed of the elite in legal lore, could not be thought of as ignorant thereof, therefore, knowingly it perpetuates instead of rectifying an injustice. Two In that case, our need for a Supreme Court would be as logical and as rational as our need for a hole in the head. Three All these proceedings are public and the media has a specially keen nose for news, particularly the most nauseating kind. Four: Our esteemed Supreme Court would be reminescent of the kangaroo court called Sandigan Bayan of Aquino-Galman shame and lead other judicial jurisdictions to believe that we are not far removed from the Marcosian practices. ISSUE: WON such statements of Atty Jacinto are clearly contemptuous and cannot be countenanced by this Court. HELD: YES. The above statements are clearly contemptuous and cannot be countenanced by this Court. Every lawyer is expected to maintain the proper decorum in his dealings with the courts of justice and is never justified in using scurrilous and threatening' language in pleading his client's cause. Impoliteness ill becomes the member of the Philippine bar. Intimidations do not suit Atty Jacinto's role as an officer of the court. While criticism of judicial conduct is not forbidden and zeal in advocacy is in fact encouraged, the lawyer must always act within the limits of propriety and good taste and with deference for the judges before whom he pleads. While professing respect for the Court, Atty. Jacinto has repeatedly insulted and threatened it in the most boorish and insolent manner He has warned it of 'a looming danger ahead" if his motions are not granted; averred that denial of his petition will make the Court as superfluous "as a hole in the head;" broadly hinted that he will then
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give the media news "of the most nauseating kind' involving the Court; and made other irresponsible charges and insinuations that besmirch the highest tribunal and undermine popular faith in its integrity. Such conduct reflects his supercilious and contemptuous regard for this Court, which cannot let his affront pass unnoticed or unpunished if similar disparagement of the administration of justice is to be avoided in the future. As by his own acts and words Atty. Jacinto has clearly demonstrated that he is unfit to continue as a member of the Philippine bar, he is excluded therefrom until he proves worthy again to enjoy the privileges of membership. Meanwhile, it is necessary to instill in him a new sense of discipline that should instruct him anew on the duty of respect he owes the courts of justice, especially this tribunal. This rehabilitation must be done outside the brotherhood he has dishonored and to which he wig be allowed to return only after he has purged himself of his misdeeds. ACCORDINGLY, Atty. Ponciano B. Jacinto is hereby SUSPENDED as a member of the Philippine bar and is prohibited from engaging in the practice of law until otherwise ordered by this Court. This resolution shall be spread in his personal record and is immediately executory. upon verbal motion of Alamacen because Almacen had already perfected an appeal to CA. But it was dismissed because MR does not contain a notice of time and place of hearing thereof therefore, a useless piece of paper, which did not interrupt the running of the period to appeal, and, consequently, the appeal was perfected out of time. Atty. Almacen then appealed to this Court by certiorari. But denied the appeal. He filed a MR and his petition for leave to file a second MR and for extension of time. But there was an entry of judgment so the motion was ordered expunged from the records. So this was why he filed his "Petition to Surrender Lawyer's Certificate of Title," in protest against what he therein asserts is "a great injustice committed against his client by this Supreme Court." He indicts this Court, "peopled by men who are calloused to our pleas for justice, who ignore without reasons their own applicable decisions and commit culpable violations of the Constitution with impunity." His client, who was deeply aggrieved by this Court's "unjust judgment," has become "one of the sacrificial victims before the altar of hypocrisy." In the same breath that he alludes to the classic symbol of justice, he ridicules the members of this Court, saying "that justice as administered by the present members of the Supreme Court is not only blind, but also deaf and dumb." He then vows to argue the cause of his client "in the people's forum," so that "the people may know of the silent injustice's committed by this Court," and that "whatever mistakes, wrongs and injustices that were committed must never be repeated." He ends his petition with a prayer that a resolution issue ordering the Clerk of Court to receive the certificate of the undersigned attorney and counsellor-at-law IN TRUST with reservation that at any time in the future and in the event we regain our faith and confidence, we may retrieve our title to assume the practice of the noblest profession. This court then required Almacen to show cause "why no disciplinary action should be taken against him." His written answer, as undignified and cynical as it is unchastened, offers -no apology. Atty. Almacen unremittingly repeats his jeremiad of lamentations, this time embellishing it with abundant sarcasm and innuendo. Almacen stands
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IN RE: ALMACEN
IN
THE MATTER OF PROCEEDINGS FOR DISCIPLINARY ACTION AGAINST ATTY. VICENTE RAUL ALMACEN Facts: CASE: Virginia Y. Yaptinchay vs. Antonio H. Calero - Atty. Vicente Almacen was counsel for the defendant. The trial court rendered judgment against his client. He moved for its reconsideration. He served on the adverse counsel a copy of the motion, but did not notify the latter of the time and place of hearing on said motion. Plaintiff moved for execution of the judgment. For "lack of proof of service," the trial court denied both motions. 2nd motion for reconsideration was filed by Almacen but withdrawn by the trial court
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four-square that his statement is borne by TRUTH and has been asserted with NO MALICE BEFORE AND AFTER THOUGHT but mainly motivated with the highest interest of justice that in the particular case of our client, the members have shown callousness to our various pleas for JUSTICE, our pleadings will bear us on this matter. Almacen rise to claim his God given right to speak the truth and his Constitutional right of free speech. Issue: W/N the statements intended to disrespect to this Court therefore should be punished Held: Yes. Suspended indefinitely Ratio: CA correctly dismissed the appeal. Almacen did not follow the "accepted and usual course of judicial proceedings,". There was, therefore, no need for this Court to exercise its supervisory power. His own negligence caused the forfeiture of the remedy of appeal, which, incidentally, is not a matter of right. It would thus appear that there is no justification for his scurrilous and scandalous outbursts. Courts treat with forbearance and restraint a lawyer who vigorously assails their actuations. Hence, as citizen and officer of the court, every lawyer is expected not only to exercise the right, but also to consider it his duty to expose the shortcomings and indiscretions of courts and judges. Every lawyer has the right to criticise but intemperate and unfair criticism is a gross violation of the duty of respect to courts. It is Such a misconduct that subjects a lawyer to disciplinary action. Rules of Court constantly remind him "to observe and maintain the respect due to courts of justice and judicial officers. The first canon of legal ethics enjoins him "to maintain towards the courts a respectful attitude, not for the sake of the temporary incumbent of the judicial office, but for the maintenance of its supreme importance." These can cause the destruction of public confidence in the integrity and orderly administration of Justice, constitute grave professional misconduct which may be visited with disbarment or other lesser appropriate disciplinary sanctions by the Supreme Court in the exercise of the prerogatives inherent in it as the duly constituted guardian of the morals and ethics of the legal fraternity. In this inquiry, the pendency or non-pendency of a case in court is altogether of no consequence. The sole objective of this proceeding is to preserve the purity of the legal profession, by removing or suspending a member whose misconduct has proved himself unfit to continue to be entrusted with the duties and responsibilities belonging to the office of an attorney.The power to discipline attorneys, who are officers of the court, is an inherent and incidental power in courts of record, and one which is essential to an orderly discharge of judicial functions. Any court having the right to admit attorneys to practice and in this state that power is vested in this court-has the inherent right, in the exercise of a sound judicial discretion to exclude them from practice. The proffered surrender of his lawyer's certificate is, of course, purely potestative on Atty. Almacen's part. Unorthodox though it may seem, no statute, no law stands in its way. Beyond making the mere offer, however, he went farther. In haughty and coarse language, he actually availed of the said move as a vehicle for his vicious tirade against this Court. Therefore, it is clear that courts has the power to punish the said acts of a lawyer. Next question is what is the nature and extent of the sanctions that may be visited upon Atty. Almacen for his transgressions. As marked out by the Rules of Court, these may range from mere suspension to total removal or disbarment. The discretion to assess the imposable sanction is primarily addressed to the sound discretion of the Court which, being neither arbitrary and despotic nor motivated by personal animosity or prejudice, should ever be controlled by the imperative need that the purity and independence of the Bar be scrupulously guarded and the dignity of and respect due to the Court be zealously maintained. That the misconduct committed by Atty. Almacen is of considerable gravity but disbarment should never be decreed where a lesser sanction would accomplish the end desired, and maybe in the future he will realize that abrasive language never fails to do disservice to an advocate
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and that in every effervescence of candor there is ample room for the added glow of respect, it is our view that suspension will suffice under the circumstances. Therefore, Atty. Vicente Raul Almacen is suspended from the practice of law until further orders, the suspension to take effect immediately. RULING: YES. Petition dismissed. RATIO: (1) Right to additional pay for work performed on Sundays and legal holidays is, by explicit articulation in Sec. 4 of the Eight-Hour Labor Law, guaranteed a workman. Consequently, failure to give additional compensation for such work is a violation of the said law. Here, the principal respondents were dismissed from their employment. But they seek reinstatement. In order that the CIR may acquire jurisdiction over a controversy in the light of R.A. No. 875, the following circumstances must be present: (1) there must exist between the parties an employer-employee relationship, or the claimant must seek his reinstatement; and (2) the controversy must relate to a case certified by the President to the CIR as one involving national interest, or must have a nearing on an unfair labor practice charge, or must arise either under the Eight-Hour Labor Law, or under the Minimum Wage Law. In default of any of these circumstances the claim becomes a mere money claim that comes under the jurisdiction of the regular courts. (2) While there was no law actually requiring payment of additional compensation for night work, the industrial court has the power to determine the wages that night workers should receive under Commonwealth Act No. 103. Work performed at night should be paid more than work done at daytime, and that if that work is done beyond the worker's regular hours of duty, he should also be paid additional compensation for overtime work. Besides, to hold that this case for extra compensation
2D 2015|
RHEEM OF THE PHILIPPINES V. FERRER

G.R. No. L-22979 January 27, 1967
PETITIONERS: Rheem of The Philippines, Inc. and Gordon W. Mackay RESPONDENTS: Zoilo R. Ferrer, Mario Tatlonghari, Santo Marilag and Court of Industrial Relations (CIR) FACTS: The CIR denied Rheem of the Philippines motion to dismiss the principal respondents' complaint and said court's refusal to reconsider the order of denial. Rheem of the Philippines, on a petition for certiorari, challenges the jurisdiction of the CIR to hear and determine a case. The petitioners are seeking the following:
1. Reinstatement with back wages, which accumulated since their illegal separation, on the ground of unjustified dismissal; 2. Payment of increase in salary and separation pay; 3. Night differential pay; and 4. Premium pay for work done on Sundays and legal holidays.
ISSUE: Whether or not the CIR has jurisdiction.
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now falls beyond the powers of the industrial court to decide, would amount to a further curtailment of the jurisdiction of said court to an extent which may defeat the purpose of the Magna Carta to the prejudice of labor. (3) The other demands are matters which arose out of the same employment. Since employer-employee relationship is sought to be re-established, the Industrial Court "has jurisdiction over all claims arising out of, or in connection with, employment". To draw a tenuous jurisdictional line is to undermine stability in labor litigations. A piecemeal resort to one court and another gives rise to multiplicity of suits. To force the employees to shuttle from one court to another to secure full redress is a situation gravely prejudicial. It is more in keeping with orderly administration of justice that all the causes of action here 'be cognizable and heard by only one court: the Court of Industrial Relations. Atty. del Mar when, as counsel for Montecillo, moved for a reconsideration with a veiled threat by mentioning the provisions of the RPC on "Knowingly rendering unjust judgment" and "judgment rendered through negligence", and the innuendo that the CA allowed itself to be deceived. When the Appellate Court denied the MR, it admonished Atty. del Mar to remember that threats and abusive language cannot compel any court of justice to grant reconsideration. del Mar persisted and in his second MR, made another threat by stating that "with almost all penal violations placed under the jurisdiction of the President of the Philippines, the next appeal will be to His Excellency, the President. The CA then ordered in a resolution for del Mar to explain within 10 days why he should not be punished for contempt of court. Del Mar made a written explanation saying that he was merely informing the Appellate Court of the course of action he would follow. On the same date, he sent a letter to the Justices informing them that he sent a letter to the President of the Philippines, furnishing them a copy thereof, and requesting the Justices to take into consideration the contents of said letter during the hearing of the case as scheduled. Not content with that move, he later on sent another letter to the same Justices wherein he reminded them of a civil case he instituted against Justices of the Supreme Court for damages in the amount of P200,000 for a decision rendered not in accordance with law and justice, stating that he would not like to do it again but would do so if provoked. INFRACTION AGAINST THE SC (FOR ISSUE #2): Del Mar's ire at the Appellate Court, turned against Us when We denied his petition for review. He filed his motion for reconsideration and wrote a letter addressed to the Clerk of this Court requesting the names of the Justices of this Court who supported the resolution denying his petition, together with the names of the Justices favoring his motion for reconsideration. After We denied his Motion for lack of merit, he then filed a manifestation stating brazenly, among other things, "I can at this time reveal to you that, had your Clerk of Court furnished me with copies of the last two Resolutions of the SC confirming the decision of the CA, I would have filed against the Justices supporting the same, civil and criminal suit as I did to the Justices of the Court of Appeals.
2D 2015|
MONTECILLO V. GICA
G.R. No. L-36800 October 21, 1974 FACTS: Jorge Montecillo was accused by Francisco Gica of oral defamation (the former allegedly calling the latter "stupid" or a "fool'). Atty. del Mar represented Montecillo and he successfully defended Monteceillo in the lower court. Del Mar was even able to win their counterclaim thus the lower court ordered Gica to pay Montecillo the adjudged moral damages. Gica appealed the award of damages to the Court of Appeals where the latter court reversed the same. The Fourth Division of the CA in a decision penned by Justice Gatmaitan and concurred in by Associate Justices Leuterio and Gaviola, reversed the lower courts decision. INFRACTION AGAINST THE CA (FOR ISSUE #1):
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Later on, in a memorandum entitled "Explanation", del Mar stated that he suffered repeated strokes of high blood pressure which rendered him dizzy and unstable mentally and physically; but reiterated that "blunders" were committed by the CAin its decision and that the Justices thereof knowingly rendered the same in violation of Article 204 of the Penal Code; that "with all the confusion prevailing nowadays, the undersigned has decided for reasons of sickness and old age to retire from the practice of law. He hopes and expects that, with the approval thereof by the SC, he could have himself released from the obligation he has contracted with his clients as regards all his pending cases." ISSUE #1: Whether or not del Mar should be suspended based on his actions towards the CA Justices RULING/RATIO: Yes. It is manifest that del Mar has scant respect for the two highest Courts of the land when on the flimsy ground of alleged error in deciding a case, he proceeded to challenge the integrity of both Courts by claiming that they knowingly rendered unjust judgment. In short, his allegation is that they acted with intent and malice, if not with gross ignorance of the law, in disposing of the case of his client. It must be pointed out that the case for damages against the Justices was terminated by compromise agreement after Mr. del Mar himself moved for the dismissal of his complaint, apologized to the Court of Appeals and the Justices concerned, and agreed to pay nominal moral damages in favor of the defendants-justices. This is the undeniable indication that respondent del Mar did not only threaten the three Justices but he actually carried out his threat, although he did not succeed in making them change their minds in the case they decided. ISSUE #2: Whether or not del Mars suspension should be affirmed based on his actions towards the SC RULING/RATIO: Yes. As an officer of the court, it is his sworn and moral duty
to help build and not destroy unnecessarily the high esteem and regard towards the court so essential to the proper administration of justice.
Through his Motion for Reconsideration, in one breath and in a language certainly not complimentary to the Appellate Court and to Us, respondent del Mar again made his veiled threat of retribution aimed at the Appellate Court and at Us for Our judicial acts. And taking heed on his memorandum entitled Explanation, and with the full realization that a practicing lawyer and officer of the court facing contempt proceedings cannot just be allowed to voluntarily retire from the practice of law. The Court, addressing the aged brethren of the bar reminded them that second only to the duty of maintaining allegiance to the Philippines and to support the Constitution and obey the laws of the Philippines, is the duty of all attorneys to observe and maintain the respect due to the courts of justice and judicial officers. It is the duty of the lawyer to maintain towards the courts a respectful attitude. As an officer of the court, it is his duty to uphold the dignity and authority of the court to which he owes fidelity, according to the oath he has taken. Respect for the courts guarantees the stability of our democratic institutions which, without such respect, would be resting on a very shaky foundation. For a lawyer in the twilight of his life, with supposed physical and mental ailments at that, who dares to challenge the integrity and honor of both the Supreme Court and Court of Appeals, We have nothing but commiseration and sympathy for his choosing to close the book of his long years of law practice not by voluntary retirement with honor but in disciplinary action with ignominy and dishonor. To those who are in the practice of law and those who in the future will choose to enter this profession, We wish to point to this case as a reminder for them to imprint in their hearts and minds that an attorney owes it to himself to respect the courts of justice and its officers as a fealty for the stability of our democratic institutions.
BALAOING V. CALDERON
Facts:
2D 2015|
[22]

This is the latest of the several administrative complaints filed by Atty. Eduardo R. Balaoing against different judges of Olongapo City and Zambales. The first complaint was filed against Jaime Dohillo as Judge of MTC in Cities, Olongapo City but was dismissed for lack of merit. Atty. Balaoing was required to show cause why he should not be disciplinary dealt with for having suppressed certain material facts of which he was charged with knowledge and for engaging in forum shopping. His explanation was also declared unsatisfactory and he was severely censured for having instituted a patently unfounded administrative action and was warned that the commission of a similar conduct will be dealt with more severely. The second complaint was filed against Judge Santiago Maliwanag in RTC of Zambales and the clerk of court charging them with grave misconduct for their alleged failure and refusal to issue the corresponding writ of execution prayed by the complaint in his motion filed in another case. The Court was disturbed by Atty. Balaoings unrestrained use of defamatory language against respondent Judge. The complaint was dismissed and he was suspended from the practice of law for 1 year. Notwithstanding the above warnings, Atty. Balaoing is again before this court with more administrative complaint filed against 2 judges, Calderon of Olongapo City and Maliwanag of Zambales. He charged Judge Calderon with misconduct, grave abuse of authority and malicious delay in the administration of justice. He alleges that the judge has been maliciously delaying the disposition of several cases pending in his sala. Another complaint was filed by Balaoing against Judge Calderon and his OIC Maniago charging them both with misconduct, grave abuse of authority and malicious delay in administration of justice relative to 2 cases. Judge Calderon contended that the present complaint against him was precipitated by incidents in a civil case entitled Balaoing vs. Gavilan for damages wherein Gavilan defaulted. All the other cases mentioned were just included to merely embellish the charges. In the Gavilan case, Balaoing won in a foreclosure case against Gavilan. After the foreclosed properties were sold in a public auction, where Balaoing was the highest bidder, a Certificate of Sale was issued. But Judge Calderon allegedly prevented the implementation of the writ of possession. He explained that the reason why he quashed the writ of possession was due to the fact the Gavilas widow and her children were residing in the properties and the period to redeem the properties had not yet expired. So this action of Judge Calderon infuriated Balaoing. Hence his filing of several suits. When the redemption period had expired, respondent Judge issued the writ of possession but up to the present time, Balaoing has not yet taken possession of the same. As to the application of Balaoing for a writ of injunction and restraining order in another civil case, respondent Judge explains that before he could finish hearing the evidence of the parties, Balaoing filed another motion for inhibition of respondent Judge to hear his cases. But respondent Judge denied the motion for failure of Balaoing to show a clear right over the property. Consolidated with this case is another case filed against Judge Maliwanag wherein he was charged with gross ignorance of the law for issuing a patently unjust order. Judge Maliwang denied it and alleged that his order was based on jurisprudence and in order to prevent an unjust and inequitable execution of the judgment. Issue: WON the complaints of Atty. Balaoing are frivolous and baseless. Held: Yes. The complaint is dismissed and Balaoing is disbarred and his name ordered stricken from the Roll of Attorneys. Ratio: Balaoing has a penchant for filing administrative charges against judges, in whose sala he has pending cases, whenever the latter render decisions or issue orders adverse to him or his clients. It is true that the lawyer owes entire devotion to the interest of the client, warm zeal in the maintenance and defense of his rights and exertion of his utmost learning and ability. But it is to
2D 2015|
[23]

be borne in mind that the great trust of the lawyer is to be performed within and not without the bounds of the law. He must obey his own conscience and not that of his client. Complainant went out of bounds when he filed his baseless and frivolous administrative complaints against respondent Judges with no other plain and clear purpose than to harass them and exact vengeance on them for rendering adverse judgments against him and his clients. Code of Professional Responsibility: 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. Rule 11.04 A lawyer shall not attribute to a Judge motives not supported by the record or have no materiality to the case. His present complaints are based on his personal interpretation of the law and not on material allegations of fact, substantiated by solid evidence. His wanton disregard of the courts stern warning not to again file baseless complaints which only clog the already full dockets of this court instead of serving the ends of justice and his refusal to abide by the CPR have shown complainants unfitness to hold the license to practice law. FACTS: Respondent Napoleon A. Abiera of the Public Attorney's Office alleged that petitioner had falsified his Certificate of Service by certifying "that all civil and criminal cases which have been submitted for decision or determination for a period of 90 days have been determined and decided on or before January 31, 1998," when in truth and in fact, petitioner knew that no decision had been rendered in five (5) civil and ten (10) criminal cases that have been submitted for decision. Respondent Abiera further alleged that petitioner similarly falsified his certificates of service for the months of February, April, May, June, July and August, all in 1989; and the months beginning January up to September 1990, or for a total of seventeen (17) months. Petitioner contends that that the Ombudsman has no jurisdiction over said case since the offense charged arose from the judge's performance of his official duties, which is under the control and supervision of the Supreme Court. Furthermore, the investigation of the Ombudsman constitutes an encroachment into the Supreme Court's constitutional duty of supervision over all inferior courts. ISSUE: Whether the investigation made by the Ombudsman constitutes an encroachment into the SCs constitutional duty of supervision over all inferior courts. Yes RULING: Article VIII, section 6 of the 1987 Constitution exclusively vests in the Supreme Court administrative supervision over all courts and court personnel, from the Presiding Justice of the Court of Appeals down to the lowest municipal trial court clerk. By virtue of this power, it is only the Supreme Court that can oversee the judges' and court personnel's compliance with all laws, and take the proper administrative action against them if they commit any violation thereof. No other branch of
2D 2015|
MACEDA V. ABIERRA
BONIFACIO SANZ MACEDA, Presiding Judge, Branch 12, Regional Trial Court, Antique, petitioner, vs. HON. OMBUDSMAN CONRADO M. VASQUEZ AND ATTY. NAPOLEON A. ABIERA, respondents. G.R. No. 102781. April 22, 1993.
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government may intrude into this power, without running afoul of the doctrine of separation of powers. A judge who falsifies his certificate of service is administratively liable to the Supreme Court for serious misconduct and inefficiency under Section 1, Rule 140 of the Rules of Court, and criminally liable to the State under the Revised Penal Code for his felonious act. In the absence of any administrative action taken against him by this Court with regard to his certificates of service, the investigation being conducted by the Ombudsman encroaches into the Court's power of administrative supervision over all courts and its personnel, in violation of the doctrine of separation of powers. In fine, where a criminal complaint against a Judge or other court employee arises from their administrative duties, the Ombudsman must defer action on said complaint and refer the same to this Court for determination whether said Judge or court employee had acted within the scope of their administrative duties. The Ombudsman is hereby directed to dismiss the complaint filed by public respondent Atty. Napoleon A. Abiera and to refer the same to this Court for appropriate action.
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LEGAL ETHICS CASE DIGESTS

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L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS CONTENTS

L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

CANDOR AND FAIRNESS (CANON 10)

HEIRS OF HERMAN RAY ROMERO V. REYES

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IN RE: 1989 ELECTION OF IBP

L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

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L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

ARTIAGA, JR. V. VILLANUENA

L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

ISSUE: W/N Quasha is entitled to a portion of the goods or its proceeds?

SURIGAO V. CLORIBAL (MISSING) ADEZ REALTY, INC. V. COURT OF APPEALS

L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

SEEING THE JUDGE IN CHAMBERS (RULE 13.01)

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RESPECT TO COURT/DISCIPLINARY (CANON 11) AUTHORITY OF THE COURT

L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

IN RE: PONCIANO B. JACINTO

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L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

L E G AL E TH ICS C AS E D I GE ST S | OBLIGATION TO COURTS

RHEEM OF THE PHILIPPINES V. FERRER

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