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Case digest Atty. Edita Noe-Lacsamana vs. Atty. Yolando F.

Busmente AC no 7269 November 23 2011

Facts: During the pendency of a certain civil case. Atty. Lacsamana discovered that her adverse counsel,
Atty. Busmente, is aided by a non-lawyer, using the name “Atty. Dela Rosa”, as collaborating counsel.
Atty. Lacsamana alleged that “Atty. Dela Rosa” is a law graduate and is the paralegal assistant of Atty.
Busmente for a few years. Atty. Lacsamana filed a complaint against Atty. Busmente assisting in the
unauthorized practice of law.

Issue: Whether or not Atty. Busmente is guilty in assisting the unauthorized practice of law.

Ruling: Canon 9 of the Code of Professional Responsibility states that no lawyer shall directly or
indirectly assist in the unauthorized practice of law. The court ruled that practice of law shall only be
limited to individuals duly qualified. The purpose is to protect the public from incompetent or dishonest
administration of justice. Wherefore Atty. Busmente is guilty of violating the Code of Professional
Responsibility and suspend from the practice of law for 6 months.

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