Director of Religious Affairs vs Estanislao

Bayot
74 Phil 579 Legal Ethics Malpractice
FACTS

In June 1943, Bayot advertised in a newspaper that he helps people in securing marriage
licenses; that he does so avoiding delays and publicity; that he also makes marriage
arrangements; that legal consultations are free for the poor; and that everything is
confidential. The Director of Religious Affairs took notice of the ad and so he sued Bayot for
Malpractice.

Bayot initially denied having published the advertisement. But later, he admitted the same
and asked for the courts mercy as he promised to never repeat the act again.

ISSUE: Whether or not Bayot is guilty of Malpractice.

HELD: Yes. Section 25 of Rule 127 expressly provides among other things that the practice
of soliciting cases at law for the purpose of gain, either personally or thru paid agents or
brokers, constitutes malpractice. The advertisement he caused to be published is a brazen
solicitation of business from the public. . It is highly unethical for an attorney to advertise
his talents or skill as a merchant advertises his marketable skills. The Supreme Court again
emphasized that best advertisement for a lawyer is the establishment of a well-merited
reputation for professional capacity and fidelity to trust. But because of Bayots plea for
leniency and his promise and the fact that he did not earn any case by reason of the ad, the
Supreme Court merely reprimanded him.