2022 FORECAST Legal Ethics

LEGAL ETHICS
from the doctrines and cases cited

during the lecture of Dep. Comm. Erickson H. Balmes
Oct. 14, 2022
As the administrative assistant of the presiding judge, it was Rota’s duty to diligently supervise
and manage court dockets and records, and to ensure that the records were complete and
intact.
As regards Rota, we agree with the Office of the Court Administrator that she is liable for gross
neglect of duty. By Rota’s own admission, she failed to refer the case to Judge Walse-Lutero for
resolution of the pending incidents “even with the intermittent follow-ups of the . . . parties.”
She likewise failed to report to Judge Walse-Lutero the damage in the records, thus, preventing
the reconstitution of the records at the earliest time possible. As the administrative assistant of
the presiding judge, it was Rota’s duty to diligently supervise and manage court dockets and
records, and to ensure that the records were complete and intact. She played a key role in the
complement of the court and could not be permitted to slacken in her job. Rapsing vs. Walse-
Lutero, 296, A.M. No. MTJ-17-1894 April 4, 2017
The volume of work cannot be an excuse for her being remiss in the performance of her
functions. By her assumption of the position of clerk of court, it is understood that she was
ready and competent to do her job with utmost devotion and efficiency.
Despite these serious charges of incompetence and unsatisfactory performance against her, the
only explanation that Rota could offer was the high volume of caseload in the court. The volume
of work, however, cannot be an excuse for her being remiss in the performance of her functions.
By her assumption of the position of clerk of court, it is understood that she was ready and
competent to do her job with utmost devotion and efficiency. Rota’s apathy towards her duties
and responsibilities as Branch Clerk of Court is inimical to the prompt and proper administration
of justice. Rapsing vs. Walse-Lutero, 296, A.M. No. MTJ-17-1894 April 4, 2017
Definition of simple neglect of duty
Simple neglect of duty is defined as the failure of an employee to give one’s attention to a task
expected of him or her. Gross neglect of duty is such neglect which, “from the gravity of the case
or the frequency of instances, becomes so serious in its character as to endanger or threaten the
public welfare.” Rapsing vs. Walse-Lutero, 296, A.M. No. MTJ-17-1894 April 4, 2017
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Rota had been given enough time to improve and reform. Despite these opportunities, and the
Supreme Court’s (SC’s) previous sanctions and repeated warnings that similar acts would be
severely dealt with, Rota had not improved in her performance as Branch Clerk of Court.
The previous warnings from this Court did not effectively rouse Rota to be more mindful of her
duties. Judge Walse-Lutero had clearly expressed her dissatisfaction with Rota’s performance
and gave her unsatisfactory performance evaluation ratings. Rota was asked twice to explain why
she should not be dropped from the service for her incompetence and negligence. Judge Walse-
Lutero had even elevated the issue of Rota’s incompetence before the Office of the Court
Administrator many times. Rota had not given any satisfactory explanation. Rapsing vs. Walse-
Lutero, 296, A.M. No. MTJ-17-1894 April 4, 2017
Clerks of Court are at the forefront of judicial administration because of their indispensable role
in case adjudication and court management.
They are the models for the court employees “to act speedily and with dispatch on their assigned
task[s] to avoid the clogging of cases in court and thereby assist in the administration of justice
without undue delay.” Moreover, as public officers, they should discharge their tasks with utmost
responsibility, integrity, loyalty, and efficiency guided by the principle that “public office is a
public trust.” Rapsing vs. Walse-Lutero, 296, A.M. No. MTJ-17-1894 April 4, 2017
The frequency by which Rota neglected her duties and her lack of remorse reveal that there is
no more justification for her to stay longer in her position.
Rota clearly failed to meet the requirements expected of her as a Branch Clerk of Court. Her
apathy evinces an utter lack of concern for her role as a “sentinel of justice.” Her repeated
infractions “seriously compromise[d] efficiency and hamper[ed] public service.” Rapsing vs.
Walse-Lutero, 296, A.M. No. MTJ-17-1894 April 4, 2017
Respondent’s incompetence and repeated infractions exhibited her unfitness, and plain
inability to discharge the duties of a Branch Clerk of Court, which justifies her dismissal from
service.
Considering Rota’s gross dereliction of duty and her violation of the Code of Conduct for Court
Personnel, the corresponding penalty of dismissal from service must be meted out to her. The

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objective of imposing the correct disciplinary measure is not so much to punish the erring officer
or employee but primarily to improve public service and preserve the public’s faith and
confidence in the government. Respondent’s incompetence and repeated infractions exhibited
her unfitness, and plain inability to discharge the duties of a Branch Clerk of Court, which justifies
her dismissal from service. Rapsing vs. Walse-Lutero, 296, A.M. No. MTJ-17-1894 April 4, 2017
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The conduct of court personnel, from the presiding judge to the lowliest clerk, must always be
beyond reproach and must be circumscribed with the heavy burden of responsibility as to let
them be free from any suspicion that may taint the Judiciary.
No other office in the government service exacts a greater demand for moral righteousness and
uprightness from an employee than the Judiciary. Thus, this Court has often stated that the
conduct of court personnel, from the presiding judge to the lowliest clerk, must always be beyond
reproach and must be circumscribed with the heavy burden of responsibility as to let them be
free from any suspicion that may taint the Judiciary. Office of the Court Administrator vs.
Silongan, 801 SCRA 280, A.M. No. P-13-3137 August 23, 2016
Gravity of gross misconduct and dishonesty
The Revised Rules on Administrative Cases in the Civil Service provide that gross misconduct and
dishonesty are grave offenses punishable by dismissal even for the first offense. Office of the
Court Administrator vs. Silongan, 801 SCRA 280, A.M. No. P-13-3137 August 23, 2016
In order for the Court to acquire jurisdiction over an administrative case, the complaint must
be filed during the incumbency of the respondent public official or employee.
It is well-settled that in order for the Court to acquire jurisdiction over an administrative case,
the complaint must be filed during the incumbency of the respondent public official or employee.
Office of the Court Administrator vs. Silongan, 801 SCRA 280, A.M. No. P-13-3137 August 23,
2016

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The practice of law is a privilege burdened with conditions—it is so delicately affected with
public interest that it is both a power and a duty of the State (through this Court) to control and
regulate it in order to protect and promote the public welfare.
Adherence to rigid standards of mental fitness, maintenance of the highest degree of morality,
faithful observance of the rules of the legal profession, compliance with the mandatory
continuing legal education requirement and payment of membership fees to the Integrated Bar
of the Philippines (IBP) are the conditions required for membership in good standing in the bar
and for enjoying the privilege to practice law. Any breach by a lawyer of any of these conditions
makes him unworthy of the trust and confidence which the courts and clients repose in him for
the continued exercise of his professional privilege. Petition for Leave to Resume Practice of
Law, Benjamin M. Dacanay, 540 SCRA 424, B.M. No. 1678 December 17, 2007
The loss of Filipino citizenship ipso jure terminates the privilege to practice law in the
Philippines—the practice of law is a privilege denied to foreigners—except when Filipino
citizenship is lost by reason of naturalization as a citizen of another country but subsequently
reacquired pursuant to RA 9225.
The Constitution provides that the practice of all professions in the Philippines shall be limited to
Filipino citizens save in cases prescribed by law. Since Filipino citizenship is a requirement for
admission to the bar, loss thereof terminates membership in the Philippine bar and,
consequently, the privilege to engage in the practice of law. In other words, the loss of Filipino
citizenship ipso jure terminates the privilege to practice law in the Philippines. The practice of
law is a privilege denied to foreigners. The exception is when Filipino citizenship is lost by reason
of naturalization as a citizen of another country but subsequently reacquired pursuant to RA
9225. This is because “all Philippine citizens who become citizens of another country shall be
deemed not to have lost their Philippine citizenship under the conditions of [RA 9225].”
Therefore, a Filipino lawyer who becomes a citizen of another country is deemed never to have
lost his Philippine citizenship if he reacquires it in accordance with RA 9225. Although he is also
deemed never to have terminated his membership in the Philippine bar, no automatic right to
resume law practice accrues. Petition for Leave to Resume Practice of Law, Benjamin M.
Dacanay, 540 SCRA 424, B.M. No. 1678 December 17, 2007

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Before a lawyer who reacquires Filipino citizenship pursuant to RA 9225 can resume his
practice, he must first secure from the Supreme Court the authority to do so.
Under RA 9225, if a person intends to practice the legal profession in the Philippines and he
reacquires his Filipino citizenship pursuant to its provisions “(he) shall apply with the proper
authority for a license or permit to engage in such practice.” Stated otherwise, before a lawyer
who reacquires Filipino citizenship pursuant to RA 9225 can resume his law practice, he must first
secure from this Court the authority to do so, conditioned on: (a) the updating and payment in
full of the annual membership dues in the IBP; (b) the payment of professional tax; (c) the
completion of at least 36 credit hours of mandatory continuing legal education; this is specially
significant to refresh the applicant/petitioner’s knowledge of Philip-pine laws and update him of
legal developments and (d) the retaking of the lawyer’s oath which will not only remind him of
his duties and responsibilities as a lawyer and as an officer of the Court, but also renew his pledge
to maintain allegiance to the Republic of the Philippines. Petition for Leave to Resume Practice
of Law, Benjamin M. Dacanay, 540 SCRA 424, B.M. No. 1678 December 17, 2007
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The party acknowledging must appear before the notary public or any other person authorized
to take acknowledgments of instruments or documents.
It is clear that the party acknowledging must appear before the notary public or any other person
authorized to take acknowledgments of instruments or documents. In the case at bar, the jurat
of the Affidavit of Loss stated that Candelaria subscribed to the affidavit before respondent on
April 29, 1994, at Mandaue City. Candelaria, however, was already dead since March 26, 1991.
Hence, it is clear that the jurat was made in violation of the notarial law. Indeed, respondent
averred in his position paper before the IBP that he did not in fact know Candelaria personally
before, during and after the notarization thus admitting that Candelaria was not present when
he notarized the documents. Ang vs. Gupana, 715 SCRA 319, A.C. No. 4545 February 5, 2014
Notarization converts a private document into a public document thus making that document
admissible in evidence without further proof of its authenticity.
Time and again, we have held that notarization of a document is not an empty act or routine.
Thus, in Bernardo v. Atty. Ramos, 383 SCRA 498 (2002), the Court emphasized the significance of

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the act of notarization, to wit: The importance attached to the act of notarization cannot be
overemphasized. Notarization is not an empty, meaningless, routinary act. It is invested with
substantive public interest, such that only those who are qualified or authorized may act as
notaries public. Notarization converts a private document into a public document thus making
that document admissible in evidence without further proof of its authenticity. A notarial
document is by law entitled to full faith and credit upon its face. Courts, administrative agencies
and the public at large must be able to rely upon the acknowledgment executed by a notary
public and appended to a private instrument. For this reason notaries public must observe with
utmost care the basic requirements in the performance of their duties. Otherwise, the confidence
of the public in the integrity of this form of conveyance would be undermined. Hence a notary
public should not notarize a document unless the persons who signed the same are the very same
persons who executed and personally appeared before him to attest to the contents and truth
of what are stated therein. The purpose of this requirement is to enable the notary public to
verify the genuineness of the signature of the acknowledging party and to ascertain that the
document is the party’s free act and deed. Ang vs. Gupana, 715 SCRA 319, A.C. No. 4545
February 5, 2014
Where the notary public is a lawyer, a graver responsibility is placed upon his shoulder by
reason of his solemn oath to obey the laws and to do no falsehood or consent to the doing of
any.
As a lawyer commissioned as notary public, respondent is mandated to subscribe to the sacred

duties appertaining to his office, such duties being dictated by public policy impressed with public
interest. Faithful observance and utmost respect of the legal solemnity of the oath in an
acknowledgment or jurat is sacrosanct. Simply put, such responsibility is incumbent upon
respondent and failing therein, he must now accept the commensurate consequences of his
professional indiscretion. As the Court has held in Flores v. Chua, 306 SCRA 465 (1999), Where
the notary public is a lawyer, a graver responsibility is placed upon his shoulder by reason of his
solemn oath to obey the laws and to do no falsehood or consent to the doing of any. The Code
of Professional Responsibility also commands him not to engage in unlawful, dishonest, immoral
or deceitful conduct and to uphold at all times the integrity and dignity of the legal profession.
Ang vs. Gupana, 715 SCRA 319, A.C. No. 4545 February 5, 2014

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A lawyer shall not delegate to any unqualified person the performance of any task which by
law may only be performed by a member of the Bar in good standing.
Respondent likewise violated Rule 9.01, Canon 9, of the Code of Professional Responsibility which
provides that “[a] lawyer shall not delegate to any unqualified person the performance of any
task which by law may only be performed by a member of the Bar in good standing.” Respondent
averred in his position paper that it had been his consistent practice to course through clerical
staff documents to be notarized. Upon referral, said clerical staff investigates whether the
documents are complete as to the fundamental requirements and inquires as to the identity of
the individual signatories thereto. If everything is in order, they ask the parties to sign the
documents and forward them to him and he again inquires about the identities of the parties
before affixing his notarial signature. It is also his clerical staff who records entries in his notarial
report. As aforesaid, respondent is mandated to observe with utmost care the basic
requirements in the performance of his duties as a notary and to ascertain that the persons who
signed the documents are the very same persons who executed and personally appeared before
him to attest to the contents and truth of what are stated therein. In merely relying on his clerical
staff to determine the completeness of documents brought to him for notarization, limiting his
participation in the notarization process to simply inquiring about the identities of the persons
appearing before him, and in notarizing an affidavit executed by a dead person, respondent is
liable for misconduct. Under the facts and circumstances of the case, the revocation of his
notarial commission, disqualification from being commissioned as a notary public for a period of
two years and suspension from the practice of law for one year are in order. Ang vs. Gupana,
715 SCRA 319, A.C. No. 4545 February 5, 2014
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A notary public should not notarize a document unless the persons who signed the same are
the very same persons who executed and personally appeared before the said notary public to
attest to the contents and truth of what are stated therein.
The presence of the parties to the deed making the acknowledgment will enable the notary public
to verify the genuineness of the signature of the affiant. A notary public is enjoined from
notarizing a fictitious or spurious document. The function of a notary public, is among others, to
guard against any illegal deed. Gonzales vs. Ramos, 460 SCRA 352, A.C. No. 6649 June 21, 2005

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When a notary public certifies to the due execution and delivery of a document under his hand
and seal, he gives the document the force of evidence—hence, a notary public must discharge
his powers and duties, which are impressed with public interest, with accuracy and fidelity.
By affixing his notarial seal on the instrument, the respondent converted the Deed of Absolute
Sale, from a private document into a public document. Such act is no empty gesture. The principal
function of a notary public is to authenticate documents. When a notary public certifies to the
due execution and delivery of a document under his hand and seal, he gives the document the
force of evidence. Indeed, one of the purposes of requiring documents to be acknowledged
before a notary public, in addition to the solemnity which should surround the execution and
delivery of documents, is to authorize such documents to be given without further proof of their
execution and delivery. A notarial document is by law entitled to full faith and credit upon its
face. Courts, administrative agencies and the public at large must be able to rely upon the
acknowledgement executed before a notary public and appended to a private instrument. Hence,
a notary public must discharge his powers and duties, which are impressed with public interest,
with accuracy and fidelity. Gonzales vs. Ramos, 460 SCRA 352, A.C. No. 6649 June 21, 2005
Respondent’s act of notarizing the acknowledgment of a deed of sale even if one of the
signatories therein did not personally appear before him clearly falls short of the yardstick of
accuracy and fidelity.
The respondent himself admitted his professional shortcomings when he said that all he did to
ascertain the authenticity of the signature of the complainant was to compare her signature on
the Deed of Absolute Sale with her other signatures on pleadings on file with him. Such conduct
of the respondent runs contrary to the express wordings of the acknowledgment in the deed of
sale. Gonzales vs. Ramos, 460 SCRA 352, A.C. No. 6649 June 21, 2005
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Time and again, we have reminded lawyers commissioned as notaries public that the affiants
must personally appear before them.
Time and again, we have reminded lawyers commissioned as notaries public that the affiants
must personally appear before them. Section 1 of Public Act No. 2103, or the Notarial Law,
provides: Section 1. (a) The acknowledgement shall be before a notary public or an officer duly

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authorized by law of the country to take acknowledgements of instruments or documents in the

place where the act is done. The notary public or the officer taking the acknowledgement shall
certify that the person acknowledging the instrument or document is known to him and that he
is the same person who executed it, acknowledged that the same is his free act and deed. The
certificate shall be made under the official seal, if he is required by law to keep a seal, and if not,
his certificate shall so state. Angeles vs. Ibañez, 576 SCRA 90, A.C. No. 7860 January 15, 2009
The physical presence of the affiants enables the notary public to verify the genuineness of the
signatures of the acknowledging parties and to ascertain that the document is the parties’ free
act and deed.
Section 2(b) of Rule IV of the Rules on Notarial Practice of 2004 reads: A person shall not perform
a notarial act if the person involved as signatory to the instrument or document—(1) is not in the
notary’s presence personally at the time of the notarization; and (2) is not personally known to
the notary public or otherwise identified by the notary public through competent evidence of
identity as defined by these Rules. The physical presence of the affiants enables the notary public
to verify the genuineness of the signatures of the acknowledging parties and to ascertain that
the document is the parties’ free act and deed. Notarization of a private document converts such
document into a public one, and renders it admissible in court without further proof of its
authenticity. Courts, administrative agencies and the public at large must be able to rely upon
the acknowledgment executed by a notary public and appended to a private instrument.
Notarization is not an empty routine; to the contrary, it engages public interest in a substantial
degree and the protection of that interest requires preventing those who are not qualified or
authorized to act as notaries public from imposing upon the public and the courts and
administrative offices generally. Angeles vs. Ibañez, 576 SCRA 90, A.C. No. 7860 January 15,
2009
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A notary public should not notarize a document unless the person who signed the same is the
very same person who executed and personally appeared before him to attest to the contents
and the truth of what are stated therein.
Without the appearance of the person who actually executed the document in question, the
notary public would be unable to verify the genuineness of the signature of the acknowledging

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party and to ascertain that the document is the party’s free act or deed. Agbulos vs. Viray, 691
SCRA 1, A.C. No. 7350 February 18, 2013
Notarization is not an empty, meaningless routinary act but one invested with substantive
public interest.
The Court has repeatedly emphasized in a number of cases the important role a notary public
performs, to wit: x x x [N]otarization is not an empty, meaningless routinary act but one invested
with substantive public interest. The notarization by a notary public converts a private document
into a public document, making it admissible in evidence without further proof of its authenticity.
A notarized document is, by law, entitled to full faith and credit upon its face. It is for this reason
that a notary public must observe with utmost care the basic requirements in the performance
of his duties; otherwise, the public’s confidence in the integrity of a notarized document would
be undermined. Agbulos vs. Viray, 691 SCRA 1, A.C. No. 7350 February 18, 2013
The responsibility to faithfully observe and respect the legal solemnity of the oath in an
acknowledgment or jurat is more pronounced when the notary public is a lawyer because of
his solemn oath under the Code of Professional Responsibility to obey the laws and to do no
falsehood or consent to the doing of any.
Respondent’s failure to perform his duty as a notary public resulted not only damage to those
directly affected by the notarized document but also in undermining the integrity of a notary
public and in degrading the function of notarization. He should, thus, be held liable for such
negligence not only as a notary public but also as a lawyer. The responsibility to faithfully observe
and respect the legal solemnity of the oath in an acknowledgment or jurat is more pronounced
when the notary public is a lawyer because of his solemn oath under the Code of Professional
Responsibility to obey the laws and to do no falsehood or consent to the doing of any. Lawyers
commissioned as notaries public are mandated to discharge with fidelity the duties of their
offices, such duties being dictated by public policy and impressed with public interest. Agbulos
vs. Viray, 691 SCRA 1, A.C. No. 7350 February 18, 2013

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Based on existing jurisprudence, when a lawyer commissioned as a notary public fails to

discharge his duties as such, he is meted the penalties of revocation of his notarial commission,
disqualification from being commissioned as a notary public for a period of two years, and
suspension from the practice of law for one year.
As to the proper penalty, the Court finds the need to increase that recommended by the IBP
which is one month suspension as a lawyer and six months suspension as notary public,
considering that respondent himself prepared the document, and he performed the notarial act
without the personal appearance of the affiant and without identifying her with competent
evidence of her identity. With his indiscretion, he allowed the use of a CTC by someone who did
not own it. Worse, he allowed himself to be an instrument of fraud. Based on existing
jurisprudence, when a lawyer commissioned as a notary public fails to discharge his duties as
such, he is meted the penalties of revocation of his notarial commission, disqualification from
being commissioned as a notary public for a period of two years, and suspension from the
practice of law for one year. Agbulos vs. Viray, 691 SCRA 1, A.C. No. 7350 February 18, 2013
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An attack on a person’s citizenship may only be done through a direct action for its nullity. A
disbarment case is definitely not the proper venue to attack someone’s citizenship.
This disbarment case centers on whether Atty. Kho violated his lawyer’s oath that he shall do no
falsehood and that he shall not engage in unlawful, dishonest, immoral, or deceitful conduct.
According to complainant, a violation occurred when respondent declared in his verified
Certificate of Acceptance of Nomination that he was a natural-born Filipino citizen. Although the
question of one’s citizenship is not open to collateral attack, the Court acknowledges the IBP-
CBD’s pronouncement that it had to make a limited finding thereon, since the alleged dishonesty
hinged on this issue. We have constantly ruled that an attack on a person’s citizenship may only
be done through a direct action for its nullity. A disbarment case is definitely not the proper
venue to attack someone’s citizenship. For the lack of any ruling from a competent court on
respondent’s citizenship, this disbarment case loses its only leg to stand on and, hence, must be
dismissed. Vazquez vs. Kho, 796 SCRA 92, A.C. No. 9492 July 11, 2016
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The Supreme Court can rule based on the pleadings filed, the transcript of the case, and the
Report and Recommendation of the Investigating Commissioner.
The Court notes that Atty. Francisco did not personally appear during the mandatory
conference/hearing and was only represented by Atty. Naval. The report did not state the reason
for Atty. Francisco’s absence. A reading of the transcript showed that she had to undergo a
procedure but no medical certificate was submitted. In any case, Atty. Naval stated that Atty.
Francisco would only confirm what was taken up during the mandatory conference/hearing. The
Court can rule based on the pleadings filed, the transcript of the case, and the Report and
Recommendation of the Investigating Commissioner. Balburias vs. Francisco, 798 SCRA 442, A.C.
No. 10631 July 27, 2016
Atty. Francisco could have avoided the incident if she at least tried to talk to Balburias’s counsel
on the matter of amicable settlement of the criminal case instead of talking to Balburias
himself.
Atty. Francisco could have avoided the incident if she at least tried to talk to Balburias’s counsel
on the matter of amicable settlement of the criminal case instead of talking to Balburias himself.
Balburias misinterpreted the approach as an attempt to “buy her opponents.” We rule that
Balburias failed to satisfactorily show that Atty. Francisco acted in bad faith. Delos Santos’s
affidavit showed that Atty. Francisco immediately corrected herself when she realized that she
might have offended Balburias by saying that she was referring to the amount of the complaint.
We gathered the same impression from the affidavits of Aquino and Atty. Villanueva.
Nevertheless, we deem it proper to admonish Atty. Francisco to be more careful in dealing with
other litigants to avoid a repetition of a similar incident in the future. Balburias vs. Francisco, 798
SCRA 442, A.C. No. 10631 July 27, 2016
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The highest form of respect for judicial authority is shown by a lawyer’s obedience to court
orders and processes.
As an officer of the court, it is a lawyer’s duty to uphold the dignity and authority of the court.
The highest form of respect for judicial authority is shown by a lawyer’s obedience to court orders
and processes. Here, respondent’s conduct evidently fell short of what is expected of her as an

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officer of the court as she obviously possesses a habit of defying this Court’s orders. She willfully
disobeyed this Court when she continued her law practice despite the five-year suspension order
against her and even misrepresented herself to be another person in order to evade said penalty.
Thereafter, when she was twice ordered to comment on her continued law practice while still
suspended, nothing was heard from her despite receipt of two Resolutions from this Court.
Neither did she pay the P30,000.00 fine imposed in the September 29, 2009 Resolution. Santeco
vs. Avance, 643 SCRA 612, A.C. No. 5834 February 22, 2011
Failure to comply with Court directives constitutes gross misconduct, insubordination or

disrespect which merits a lawyer’s suspension or even disbarment.
We have held that failure to comply with Court directives constitutes gross misconduct,
insubordination or disrespect which merits a lawyer’s suspension or even disbarment. Sebastian
v. Bajar, 532 SCRA 435 (2007), teaches Respondent’s cavalier attitude in repeatedly ignoring the
orders of the Supreme Court constitutes utter disrespect to the judicial institution. Respondent’s
conduct indicates a high degree of irresponsibility. A Court’s Resolution is “not to be construed
as a mere request, nor should it be complied with partially, inadequately, or selectively.
Respondent’s obstinate refusal to comply with the Court’s orders not “only betrays a recalcitrant
flaw in her character; it also underscores her disrespect of the Court’s lawful orders which is only
too deserving of reproof.” Under Section 27, Rule 138 of the Rules of Court a member of the bar
may be disbarred or suspended from office as an attorney for gross misconduct and/or for a
willful disobedience of any lawful order of a superior court. Santeco vs. Avance, 643 SCRA 612,
A.C. No. 5834 February 22, 2011
Respondent is unfit to discharge the duties of an officer of the court and deserves the ultimate
penalty of disbarment.
In repeatedly disobeying this Court’s orders, respondent proved herself unworthy of membership
in the Philippine Bar. Worse, she remains indifferent to the need to reform herself. Clearly, she
is unfit to discharge the duties of an officer of the court and deserves the ultimate penalty of
disbarment. Santeco vs. Avance, 643 SCRA 612, A.C. No. 5834 February 22, 2011
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Penalties, such as disbarment, are imposed not to punish but to correct offenders.
Penalties, such as disbarment, are imposed not to punish but to correct offenders. While the
Court is ever mindful of its duty to discipline its erring officers, it also knows how to show
compassion when the penalty imposed has already served its purpose. In cases where we have
deigned to lift or commute the supreme penalty of disbarment imposed on the lawyer, we have
taken into account the remorse of the disbarred lawyer and the conduct of his public life during
his years outside of the bar. Re: 2003 Bar Examinations Atty. Danilo De Guzman, 586 SCRA 372,
B.M. No. 1222 April 24, 2009
Of all classes and professions, the lawyer is most sacredly bound to uphold the laws.
Petitioner’s subsequent track record in public service affords the Court some hope that if he were
to reacquire membership in the Philippine bar, his achievements as a lawyer would redound to
the general good and more than mitigate the stain on his record. Compassion to the petitioner is
warranted. Nonetheless, we wish to impart to him the following stern warning: “Of all classes
and professions, the lawyer is most sacredly bound to uphold the laws. He is their sworn servant;
and for him, of all men in the world, to repudiate and override the laws, to trample them
underfoot and to ignore the very bands of society, argues recreancy to his position and office and
sets a pernicious example to the insubordinate and dangerous elements of the body politic.” Re:
2003 Bar Examinations Atty. Danilo De Guzman, 586 SCRA 372, B.M. No. 1222 April 24, 2009
x-----------------------------------------------------------------------x
A lawyer’s personal deference to the law not only speaks of his character but it also inspires
respect and obedience to the law, on the part of the public.
Canon 1 clearly mandates the obedience of every lawyer to laws and legal processes. To the best
of his ability, a lawyer is expected to respect and abide by the law and, thus, avoid any act or
omission that is contrary thereto. A lawyer’s personal deference to the law not only speaks of his
character but it also inspires respect and obedience to the law, on the part of the public. Rule
1.0, on the other hand, states the norm of conduct to be observed by all lawyers. Jimenez vs.
Francisco, 744 SCRA 215, A.C. No. 10548 December 10, 2014

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Membership in the legal profession is bestowed upon individuals who are not only learned in
law, but also known to possess good moral character.
Lawyers should act and comport themselves with honesty and integrity in a manner beyond
reproach, in order to promote the public’s faith in the legal profession. “To say that lawyers must
at all times uphold and respect the law is to state the obvious, but such statement can never be
overemphasized. Considering that, of all classes and professions, [lawyers are] most sacredly
bound to uphold the law, it is imperative that they live by the law.” Jimenez vs. Francisco, 744
SCRA 215, A.C. No. 10548 December 10, 2014
It needs to be emphasized that the lawyer’s fidelity to his client must not be pursued at the
expense of truth and justice, and must be held within the bounds of reason and common sense.
Time and again, the Court has reminded lawyers that their support for the cause of their clients
should never be attained at the expense of truth and justice. While a lawyer owes absolute
fidelity to the cause of his client, full devotion to his genuine interest, and warm zeal in the
maintenance and defense of his rights, as well as the exertion of his utmost learning and ability,
he must do so only within the bounds of the law. It needs to be emphasized that the lawyer’s
fidelity to his client must not be pursued at the expense of truth and justice, and must be held
within the bounds of reason and common sense. His responsibility to protect and advance the
interests of his client does not warrant a course of action propelled by ill motives and malicious
intentions. Jimenez vs. Francisco, 744 SCRA 215, A.C. No. 10548 December 10, 2014
Lawyers are expected to act with honesty in all their dealings, especially with the court.
Canon 10 of the CPR provides that, “[a] lawyer owes candor, fairness and good faith to the court.”
Corollary thereto, Rule 10.0 of the CPR provides that “a lawyer shall do no falsehood, nor consent
to the doing of any in Court, nor shall he mislead or allow the Court to be misled by an artifice.”
Lawyers are officers of the court, called upon to assist in the administration of justice. They act
as vanguards of our legal system, protecting and upholding truth and the rule of law. They are
expected to act with honesty in all their dealings, especially with the court. From the foregoing,
Atty. Francisco clearly violated his duties as a lawyer embodied in the CPR, namely, to avoid
dishonest and deceitful conduct, (Rule 1.01, Canon 1) and to act with candor, fairness and good
faith (Rule 10.01, Canon 10). Also, Atty. Franciso desecrated his solemn oath not to do any
falsehood nor consent to the doing of the same. Jimenez vs. Francisco, 744 SCRA 215, A.C. No.
10548 December 10, 2014

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A client can only entrust confidential information to his/her lawyer based on an expectation
from the lawyer of utmost secrecy and discretion; the lawyer, for his part, is duty-bound to
observe candor, fairness and loyalty in all his dealings and transactions with the client. Part of
the lawyer’s duty in this regard is to avoid representing conflicting interests.
Rule 15.03, Canon 15 of the CPR provides that, “[a] lawyer shall not represent conflicting interests
except by written consent of all concerned given after a full disclosure of the facts.” “The
relationship between a lawyer and his/her client should ideally be imbued with the highest level
of trust and confidence. This is the standard of confidentiality that must prevail to promote a full
disclosure of the client’s most confidential information to his/her lawyer for an unhampered
exchange of information between them. Needless to state, a client can only entrust confidential
information to his/her lawyer based on an expectation from the lawyer of utmost secrecy and
discretion; the lawyer, for his part, is duty-bound to observe candor, fairness and loyalty in all his
dealings and transactions with the client. Part of the lawyer’s duty in this regard is to avoid
representing conflicting interests…” Thus, even if lucrative fees offered by prospective clients are
at stake, a lawyer must decline professional employment if the same would trigger a violation of
the prohibition against conflict of interest. Jimenez vs. Francisco, 744 SCRA 215, A.C. No. 10548
December 10, 2014
In suspension or disbarment proceedings, lawyers enjoy the presumption of innocence, and the
burden of proof rests upon the complainant to clearly prove the allegations in the complaint by
preponderant evidence.
Preponderance of evidence means that the evidence adduced by one side is, as a whole, superior
to or has greater weight than that of the other. It means evidence which is more convincing to
the court as worthy of belief than that which is offered in opposition thereto. Under Section 1 of
Rule 133, in determining whether or not there is preponderance of evidence, the court may
consider the following: (a) all the facts and circumstances of the case; (b) the witnesses’ manner
of testifying, their intelligence, their means and opportunity of knowing the facts to which they
are testifying, the nature of the facts to which they testify, the probability or improbability of
their testimony; (c) the witnesses’ interest or want of interest, and also their personal credibility
so far as the same may ultimately appear in the trial; and (d) the number of witnesses, although
it does not mean that preponderance is necessarily with the greater number. Jimenez vs.
Francisco, 744 SCRA 215, A.C. No. 10548 December 10, 2014

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Grounds by which a Lawyer may be Suspended or Disbarred.
A member of the Bar may be penalized, even disbarred or suspended from his office as an
attorney, for violating of the lawyer’s oath and/or for breaching the ethics of the legal profession
as embodied in the CPR, for the practice of law is a profession, a form of public trust, the
performance of which is entrusted to those who are qualified and who possess good moral
character. The appropriate penalty on an errant lawyer depends on the exercise of sound judicial
discretion based on the surrounding facts. Under Section 27, Rule 138 of the Revised Rules of
Court, a member of the Bar may be disbarred or suspended on any of the following grounds: (1)
deceit; (2) malpractice or other gross misconduct in office; (3) grossly immoral conduct; (4)
conviction of a crime involving moral turpitude; (5) violation of the lawyer’s oath; (6) willful
disobedience of any lawful order of a superior court; and (7) willful appearance as an attorney
for a party without authority. A lawyer may be disbarred or suspended for misconduct, whether
in his professional or private capacity, which shows him to be wanting in moral character,
honesty, probity and good demeanor, or unworthy to continue as an officer of the court. Jimenez
vs. Francisco, 744 SCRA 215, A.C. No. 10548 December 10, 2014
x-----------------------------------------------------------------------x
Bar Matter (BM) No. 850 requires members of the Integrated Bar of the Philippines (IBP) to
undergo continuing legal education “to ensure that throughout their career, they keep abreast
with law and jurisprudence, maintain the ethics of the profession and enhance the standards
of the practice of law.”
The First Compliance Period was from 15 April 2001 to 14 April 2004; the Second Compliance
Period was from 15 April 2004 to 14 April 2007; and the Third Compliance Period was from 15
April 2007 to 14 April 2010. Complainant’s letter covered respondent’s pleadings filed in 2009,
2010, 2011, and 2012 which means respondent also failed to comply with the MCLE requirements
for the Fourth Compliance Period from 15 April 2010 to 14 April 2013. Arnado vs. Adaza, 768
SCRA 172, A.C. No. 9834 August 26, 2015

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Respondent’s failure to comply with the Mandatory Continuing Legal Education (MCLE)
requirements and disregard of the directives of the MCLE Office warrant his declaration as a
delinquent member of the Integrated Bar of the Philippines (IBP).
Respondent’s failure to comply with the MCLE requirements and disregard of the directives of
the MCLE Office warrant his declaration as a delinquent member of the IBP. While the MCLE
Implementing Regulations state that the MCLE Committee should recommend to the IBP Board
of Governors the listing of a lawyer as a delinquent member, there is nothing that prevents the
Court from using its administrative power and supervision to discipline erring lawyers and from
directing the IBP Board of Governors to declare such lawyers as delinquent members of the IBP.
Arnado vs. Adaza, 768 SCRA 172, A.C. No. 9834 August 26, 2015
The Supreme Court (SC) deems it proper to declare respondent as a delinquent member of the
Integrated Bar of the Philippines (IBP) and to suspend him from the practice of law for six (6)
months or until he has fully complied with the requirements of the Mandatory Continuing Legal
Education (MCLE) for the First, Second, Third, and Fourth Compliance Periods, whichever is
later, and he has fully paid the required noncompliance and reinstatement fees.
The OBC recommended respondent’s suspension from the practice of law for six months. We
agree. In addition, his listing as a delinquent member of the IBP is also akin to suspension because
he shall not be permitted to practice law until such time as he submits proof of full compliance
to the IBP Board of Governors, and the IBP Board of Governors has notified the MCLE Committee
of his reinstatement, under Section 14 of the MCLE Implementing Regulations. Hence, we deem
it proper to declare respondent as a delinquent member of the IBP and to suspend him from the
practice of law for six months or until he has fully complied with the requirements of the MCLE
for the First, Second, Third, and Fourth Compliance Periods, whichever is later, and he has fully
paid the required noncompliance and reinstatement fees. Arnado vs. Adaza, 768 SCRA 172, A.C.
No. 9834 August 26, 2015
x-----------------------------------------------------------------------x

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Under Section 6, Rule 138 of the Rules of Court, no applicant for admission to the Bar
Examination shall be admitted unless he had pursued and satisfactorily completed a pre-law
course.
The IBP was also correct in ordering that respondent, whose real name is “Richard A. Caronan,”
be barred from admission to the Bar. Under Section 6, Rule 138 of the Rules of Court, no applicant
for admission to the Bar Examination shall be admitted unless he had pursued and satisfactorily
completed a pre-law course, viz.: Section 6. Pre-Law.—No applicant for admission to the bar
examination shall be admitted unless he presents a certificate that he has satisfied the Secretary
of Education that, before he began the study of law, he had pursued and satisfactorily completed
in an authorized and recognized university or college, requiring for admission thereto the
completion of a four-year high school course, the course of study prescribed therein for a
bachelor’s degree in arts or sciences with any of the following subject as major or field of
concentration: political science, logic, english, Spanish, history, and economics. (Emphases
supplied) In the case at hand, respondent never completed his college degree. While he enrolled
at the PLM in 1991, he left a year later and entered the PMA where he was discharged in 1993
without graduating. Clearly, respondent has not completed the requisite pre-law degree.
Caronan vs. Caronan, 796 SCRA 376, A.C. No. 11316 July 12, 2016
Respondent’s false assumption of his brother’s name, identity, and educational records renders
him unfit for admission to the Bar.
The Court does not discount the possibility that respondent may later on complete his college
education and earn a law degree under his real name. However, his false assumption of his
brother’s name, identity, and educational records renders him unfit for admission to the Bar. The
practice of law, after all, is not a natural, absolute or constitutional right to be granted to
everyone who demands it. Rather, it is a privilege limited to citizens of good moral character. In
In the Matter of the Disqualification of Bar Examinee Haron S. Meling in the 2002 Bar
Examinations and for Disciplinary Action as Member of the Philippine Shari’a Bar, Atty. Froilan R.
Melendrez, 431 SCRA 146 (2004), the Court explained the essence of good moral character: Good
moral character is what a person really is, as distinguished from good reputation or from the
opinion generally entertained of him, the estimate in which he is held by the public in the place
where he is known. Moral character is not a subjective term but one which corresponds to
objective reality. The standard of personal and professional integrity is not satisfied by such
conduct as it merely enables a person to escape the penalty of criminal law. Good moral character
includes at least common honesty. Caronan vs. Caronan, 796 SCRA 376, A.C. No. 11316 July 12,
2016

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Good moral character is essential in those who would be lawyers.
Respondent exhibited his dishonesty and utter lack of moral fitness to be a member of the Bar
when he assumed the name, identity, and school records of his own brother and dragged the
latter into controversies which eventually caused him to fear for his safety and to resign from
PSC where he had been working for years. Good moral character is essential in those who would
be lawyers. This is imperative in the nature of the office of a lawyer, the trust relation which exists
between him and his client, as well as between him and the court. Caronan vs. Caronan, 796
SCRA 376, A.C. No. 11316 July 12, 2016
Respondent made a mockery of the legal profession by pretending to have the necessary
qualifications to be a lawyer.
Respondent made a mockery of the legal profession by pretending to have the necessary
qualifications to be a lawyer. He also tarnished the image of lawyers with his alleged
unscrupulous activities, which resulted in the filing of several criminal cases against him.
Certainly, respondent and his acts do not have a place in the legal profession where one of the
primary duties of its members is to uphold its integrity and dignity. Caronan vs. Caronan, 796
SCRA 376, A.C. No. 11316 July 12, 2016
x-----------------------------------------------------------------------x
The practice of law by attorneys employed in the government, to fall within the prohibition of
statutes has been interpreted as customarily habitually holding one’s self out to the public, as
a lawyer and demanding payment for such services.
We now determine whether respondent engaged in the practice of law while employed as Legal
Officer V in the Manila Urban Settlement Office. Private practice of law contemplates a
succession of acts of the same nature habitually or customarily holding one’s self to the public as
a lawyer. Practice is more than an isolated appearance for it consists in frequent or customary
action a succession of acts of the same kind. The practice of law by attorneys employed in the
government, to fall within the prohibition of statutes has been interpreted as customarily
habitually holding one’s self out to the public, as a lawyer and demanding payment for such
services. Lorenzana vs. Fajardo, 462 SCRA 1, A.C. No. 5712 June 29, 2005

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x-----------------------------------------------------------------------x
As much as the Court will not hesitate to discipline an erring lawyer, it should, at the same time,
also ensure that a lawyer may not be deprived of the freedom and right to exercise his
profession unreasonably.
It must be remembered that the practice of law is not a right but a mere privilege and, as such,
must bow to the inherent regulatory power of the Supreme Court to exact compliance with the
lawyer’s public responsibilities. Whenever it is made to appear that an attorney is no longer
worthy of the trust and confidence of his clients and of the public, it becomes not only the right
but also the duty of the Supreme Court, which made him one of its officers and gave him the
privilege of ministering within its Bar, to withdraw that privilege. However, as much as the Court
will not hesitate to discipline an erring lawyer, it should, at the same time, also ensure that a
lawyer may not be deprived of the freedom and right to exercise his profession unreasonably.
Maniago vs. De Dios, 617 SCRA 142, A.C. No. 7472 March 30, 2010
Guidelines in the Matter of Lifting an Order of Suspending a Lawyer from the Practice of Law.
In light of the foregoing, it is hereby resolved that the following guidelines be observed in the
matter of the lifting of an order suspending a lawyer from the practice of law: 1) After a finding
that respondent lawyer must be suspended from the practice of law, the Court shall render a
decision imposing the penalty; 2) Unless the Court explicitly states that the decision is
immediately executory upon receipt thereof, respondent has 15 days within which to file a
motion for reconsideration thereof. The denial of said motion shall render the decision final and
executory; 3) Upon the expiration of the period of suspension, respondent shall file a Sworn
Statement with the Court, through the Office of the Bar Confidant, stating therein that he or she
has desisted from the practice of law and has not appeared in any court during the period of his
or her suspension; 4) Copies of the Sworn Statement shall be furnished to the Local Chapter of
the IBP and to the Executive Judge of the courts where respondent has pending cases handled
by him or her, and/or where he or she has appeared as counsel; 5) The Sworn Statement shall be
considered as proof of respondent’s compliance with the order of suspension; 6) Any finding or
report contrary to the statements made by the lawyer under oath shall be a ground for the
imposition of a more severe punishment, or disbarment, as may be warranted. Maniago vs. De
Dios, 617 SCRA 142, A.C. No. 7472 March 30, 2010

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x-----------------------------------------------------------------------x
A lawyer may not divide his personality so as to be an attorney at one time and a mere citizen
at another—he is expected to be competent, honorable and reliable at all times since he who
cannot apply and abide by the laws in his private affairs, can hardly be expected to do so in his
professional dealings nor lead others in doing so.
Thus we have in a number of cases disciplined members of the Bar whom we found guilty of
misconduct which demonstrated a lack of that good moral character required of them not only
as a condition precedent for their admission to the Bar but, likewise, for their continued
membership therein. No distinction has been made as to whether the misconduct was
committed in the lawyer’s professional capacity or in his private life. This is because a lawyer may
not divide his personality so as to be an attorney at one time and a mere citizen at another. He is
expected to be competent, honorable and reliable at all times since he who cannot apply and
abide by the laws in his private affairs, can hardly be expected to do so in his professional dealings
nor lead others in doing so. Professional honesty and honor are not to be expected as the
accompaniment of dishonesty and dishonor in other relations. The administration of justice, in
which the lawyer plays an important role being an officer of the court, demands a high degree of
intellectual and moral competency on his part so that the courts and clients may rightly repose
confidence in him. Bustamante-Alejandro vs. Alejandro, 422 SCRA 527, A.C. No. 4256 February
13, 2004
Disbarment proceedings is warranted against a lawyer who abandons his lawful wife and
maintains an illicit relationship with another woman.
In the instant case, sufficient evidence was presented to show that respondent Atty. Alejandro,
while being lawfully married to complainant, carried on an illicit relationship with another
woman, co-respondent Atty. Villarin. Although the evidence presented was not sufficient to
prove that he contracted a subsequent bigamous marriage with her, the fact remains that
respondent Atty. Alejandro exhibited by his conduct a deplorable lack of that degree of morality
required of him as a member of the Bar. We have already held that disbarment proceedings is
warranted against a lawyer who abandons his lawful wife and maintains an illicit relationship
with another woman who had borne him a child. We can do no less in the instant case where
respondent Atty. Alejandro made himself unavailable to this Court and even fled to another
country to escape the consequences of his misconduct. Bustamante-Alejandro vs. Alejandro,
422 SCRA 527, A.C. No. 4256 February 13, 2004

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Oct. 14, 2022
Considering the serious consequences of disbarment proceedings, full opportunity upon

reasonable notice must be given the respondent to answer the charge and present evidence in
her behalf—it is only in clear cases of waiver that an administrative case be resolved sans
respondent’s answer.
The IBP for its part attempted to serve copy of the complaint upon Atty. Villarin with directive for
her to file answer. It is noted however that the same was sent to respondent’s old address at 27-
C Masbate St., Quezon City, not “12403 Dunlop Drive, Houston, Texas,” which was respondents’
new address on record supplied by the complainant. The return of service therefore showed the
postal notation “moved”. Considering the serious consequences of disbarment proceedings, full
opportunity upon reasonable notice must have been given respondent to answer the charge and
present evidence in her behalf. It is only in clear cases of waiver that an administrative case be
resolved sans respondent’s answer. Bustamante-Alejandro vs. Alejandro, 422 SCRA 527, A.C.
No. 4256 February 13, 2004
x-----------------------------------------------------------------------x
Any lawyer who assumes the responsibility for a client's cause has the duty to know the entire
history of a case, specially if any litigation has commenced.
Any lawyer who assumes the responsibility for a client's cause has the duty to know the entire
history of a case, specially if any litigation has commenced. In the case at bar, even Atty. Montalvo
does not deny the fact that the probate of the will of the late Benedicta de Los Reyes has been
an overextended and contentious litigation between the heirs. Dimagiba vs. Montalvo, Jr., 202
SCRA 641, Adm. Case No. 1424 October 15, 1991
A lawyer should never take advantage of the seemingly endless channels left dangling by our
legal system in order to wangle the attention of the court.
A lawyer should never take advantage of the seemingly endless channels left dangling by our
legal system in order to wangle the attention of the court. Atty. Montalvo may have thought that
he could get away with his indiscriminate filing of suits that were clearly intended to harass
Ismaela Dimagiba. When court dockets get clogged and the administration of justice is delayed,
our judicial system may not be entirely blameless, yet the greater fault lies in the lawyers who
had taken their privilege so lightly, and in such mindless fashion. Dimagiba vs. Montalvo, Jr., 202
SCRA 641, Adm. Case No. 1424 October 15, 1991

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LEGAL ETHICS

from the doctrines and cases cited

Definition of simple neglect of duty

Legal Edge Bar Review 0942 – 949 91 76

Legal Edge Bar Review 0942 – 949 91 76

Gravity of gross misconduct and dishonesty

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As a lawyer commissioned as notary public, respondent is mandated to subscribe to the sacred

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authorized by law of the country to take acknowledgements of instruments or documents in the

Legal Edge Bar Review 0942 – 949 91 76

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Based on existing jurisprudence, when a lawyer commissioned as a notary public fails to

Legal Edge Bar Review 0942 – 949 91 76

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Failure to comply with Court directives constitutes gross misconduct, insubordination or

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Legal Edge Bar Review 0942 – 949 91 76

Legal Edge Bar Review 0942 – 949 91 76

Legal Edge Bar Review 0942 – 949 91 76

Grounds by which a Lawyer may be Suspended or Disbarred.

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Legal Edge Bar Review 0942 – 949 91 76

Legal Edge Bar Review 0942 – 949 91 76

Good moral character is essential in those who would be lawyers.

Legal Edge Bar Review 0942 – 949 91 76

Legal Edge Bar Review 0942 – 949 91 76

Legal Edge Bar Review 0942 – 949 91 76

Considering the serious consequences of disbarment proceedings, full opportunity upon

Legal Edge Bar Review 0942 – 949 91 76

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