2023 BAR REVIEW LEGAL & JUDICIAL ETHICS

Handout No. 9
CHAIR’S CASES

The regulation of the practice of law falls upon the exclusive jurisdiction of the High Court. As
such, a lawyer who has been suspended from the practice of law by the Court must refrain
from performing all functions which would require the application of his legal knowledge
within the period of suspension.

The practice of law includes any activity, in or out of court, which requires the application of law,
legal procedure, knowledge, training, and experience. It comprises the performance of acts
which are characteristic of the legal profession, or rendering any kind of service which requires
the use in any degree of legal knowledge or skill. Cansino v. Sederiosa, A.C. No. 8522, October
6, 2020

One's admission to the Bar is by no means a license to gloss over the loopholes in legislation,
to hijack the legal processes, or to manipulate the technical decisions of those unlearned in
law.

Among the sworn obligations of attorneys upon taking the Lawyer's Oath is to uphold the
Constitution and obey the laws of the land at all times, never to waver even if vices of luxury,
convenience, and worldly excesses tempt them so. xxx The Court finds Atty. Vitorillo guilty of
deceitful conduct proscribed by Canon 1, Rule 1.01 of the CPR. In the contract to sell that Atty.
Vitorillo himself submitted before the Court, Atty. Vitorillo expressly named himself as the seller
and absolute owner of the subject property. The verity of such contractual status rests upon a
single fact — that Atty. Vitorillo held absolute ownership over the entire 800-square-meter
subject property at the time he offered it for sale to Partsch. The facts at hand reveal that he did
not. Partsch v. Vitorillo, A.C. No. 10897, January 4, 2022

The prohibition against foreign ownership of Philippine private lands is too basic a rule for
even non-attorneys to be unaware of.

As a lawyer, Atty. Vitorillo is presumed to know this. Despite being equipped with such
knowledge, Atty. Vitorillo still marketed the subject property for sale to Partsch, a Swiss national.
More telling of Atty. Vitorillo's ethical obliquity is his questionable instruction to Partsch to just
proceed with the fencing of the subject property without any acceptable guarantee of Atty.
Vitorillo's title thereto. Again, Atty. Vitorillo had not refuted this serious allegation. He is deemed
to have acted in contravention of Canon 1, Rule 1.02 — CPR's proscription against counseling
activities aimed at defiance of the law. Partsch v. Vitorillo, A.C. No. 10897, January 4, 2022

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Issuance of a worthless check

In this case, respondent obtained a loan from complainant in the amount of P500,000.00 and in
exchange thereof issued a worthless check to complainant. This fact alone is a ground for
disciplinary action as it constitutes gross misconduct. It indicates his unfitness for the trust and
confidence reposed upon him and his lack of personal honesty and good moral character
rendering him unworthy of public confidence. In Ong v. Atty. Delos Santos, the Court explained
that a lawyer who issues a worthless check is in breach of his oath to obey the laws. The Court
explained — [BP 22] has been enacted in order to safeguard the interest of the banking system
and the legitimate public checking account users. The gravamen of the offense defined and
punished by [BP 22], according to Lozano v. Martinez, is the act of making and issuing a
worthless check, or any check that is dishonored upon its presentment for payment and putting
it in circulation; the law is designed to prohibit and altogether eliminate the deleterious and
pernicious practice of issuing checks with insufficient funds, or with no credit, because the
practice is deemed a public nuisance, a crime against public order to be abated. Andaya v.
Tumanda, A.C. No. 12209, February 18, 2020

Notarization converts a private document into a public document and makes such document
admissible as evidence without further proof of its authenticity. A notarial document is by law
entitled to full faith and credit upon its face. Consequently, notaries public must therefore
observe with utmost care the basic requirements in the performance of their duties.

We have repeatedly emphasized that notarization is not a mere 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. In other words, to protect substantive public interest,
those not qualified or authorized to act must be prevented from imposing upon the public, the
courts, and the administrative offices in general. Corollary, Section 11 of the 2004 Rules on
Notarial Practice is clear. Only a person who is commissioned as notary public may perform
notarial acts in any place within the territorial jurisdiction of the commissioning court for a
period of two (2) years commencing the first day of January of the year in which the
commissioning is made, unless earlier revoked or the notary public has resigned under
these Rules and the Rules of Court. Hence, a violation thereof should therefore not be dealt with
lightly to preserve the integrity of notarization. Manzano v. Rivera, A.C. No. 12173, November
3, 2020

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Good moral character is a continuing condition to preserve membership in the Bar in good
standing.

Atty. Rivera's misdeed further lessens the confidence and trust reposed by the public in the
fidelity, honesty and integrity of the legal profession. He is expected to possess the high
standards of morality to remain a member of the bar. In Advincula v. Macabata, we emphasized
that good moral character is a continuing condition to preserve membership in the Bar in good
standing, thus: Lawyers have been repeatedly reminded that their possession of good moral
character is a continuing condition to preserve their membership in the Bar in good standing.
The continued possession of good moral character is a requisite condition for remaining in the
practice of law. Manzano v. Rivera, A.C. No. 12173, November 3, 2020

It is settled that "notarization is not an empty, meaningless routinary act, but one invested
with substantive public interest. Notarization converts a private document into a public
document, making it admissible in evidence without further proof of its authenticity.

Thus, 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 notarial duties; otherwise, the public's confidence in the integrity of a
notarized document would be undermined." Atty. Amores is, therefore, bound to strictly comply
with these notarial rules. xxx A notary public is empowered to perform a variety of notarial acts,
one of which is a jurat. Atty. Amores performed a jurat when he notarized the Secretary's
Certificate with Irene signing as the Corporate Secretary. Kiener v. Amores, A.C. No. 9417,
November 18, 2020

Requirement of physical appearance prohibits the notary public from performing a notarial
act if the signatory is not in his/her presence at the time of the notarization.

In Prospero v. Delos Santos, the Court emphasized that "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 party and to ascertain that the document is the party's free act or deed." To
repeat, Atty. Amores failed to observe the requirement of physical presence when he notarized
the Secretary's Certificate. Upon examination of the document, and as admitted by Atty. Amores
himself, Irene's signature in the Secretary's Certificate attached to the complaint-affidavit in the

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criminal case was merely printed. In short, it was not an actual handwritten signature of Irene.
Atty. Amores's defense that Irene physically signed one copy that was subsequently reproduced
then notarized, does not convince this Court. Atty. Amores did not present any proof that Irene
was indeed physically in his presence upon the signing and notarization of the document. It goes
without saying that Irene had signed the document elsewhere, scanned it, and then sent it
electronically to Atty. Amores for the latter to print, reproduce, notarize, and use for the
designated purpose. If indeed Irene had personally appeared before him, he should have asked
her right then and there to affix her signature to each and every copy of the document, not just
to one copy. Kiener v. Amores, A.C. No. 9417, November 18, 2020

A community tax certificate (CTC) is no longer considered as competent evidence of identity.

Atty. Amores used a CTC as competent evidence of identity of Irene in notarizing the Secretary's
Certificate. However, it was not a violation at the time of the performance of the notarial act in
2007 as the use of CTCs was prohibited only in 2008 by virtue of an amendment to the Rules on
Notarial Practice as clarified in the case of Baylon v. Almo. Kiener v. Amores, A.C. No. 9417,
November 18, 2020

Guided by the foregoing on what constitutes a practice of law, it is beyond cavil that notarizing
of documents constitutes a practice of law.

A lawyer, during the period of his/her suspension, is barred from engaging in notarial practice
as he/she is deemed not a member of the Philippine Bar in good standing, which is one of the
essential requisites to be eligible as a notary public. There is more than enough evidence that
shows that Atty. Sederiosa has continuously been practicing his legal profession despite the
suspension order against him. He remained to be a duly commissioned notary public from
January 8, 2016 to December 31, 2017 as attested by the Certification from the RTC-Davao City,
the Commission for Notary Public dated January 8, 2016, and the Affidavit of Loss dated August
8, 2016 which he duly notarized. In short, he had never served his suspension. It must be
stressed that at the time he notarized the Affidavit of Loss on August 8, 2016, Atty. Sederiosa
was already cognizant of the Court's December 7, 2015 Resolution as early as January 29, 2016.
As such, he was already aware that the Court had imposed the following penalties upon him: (a)
immediate revocation of his notarial commission; (b) disqualification from being commissioned
as a notary public for a period of two years; and (c) suspension for one year from the practice of
law. Consequently, Atty. Sederiosa should have refrained from performing the duties of a notary
public and engaging in law practice. Yet, he continued to notarize documents in clear defiance
of the Court's orders. By doing so, he continued to practice law. All told, Atty. Sederiosa is

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administratively liable for engaging in law practice during his suspension and for performing his
duties as a notary public despite revocation of his commission. Cansino v. Sederiosa, A.C. No.
8522, October 6, 2020

The act of notarization is not an ordinary routine but is imbued with substantive public
interest. It converts a private document into a public document resulting in the document's
admissibility in evidence without further proof of its authenticity. A notarial document is
therefore entitled to full faith and credit on its face and by law.

It is the duty of notaries public to observe utmost care in complying with the formalities
intended to protect the integrity of the notarized document and the act or acts it embodies. The
Court, in Gonzales v. Ramos, elucidated the importance of notarization, to wit: 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. Ang v. Belaro, Jr., A.C. No. 12408, December 11, 2019

The 2004 Rules on Notarial Practice clearly states that, when not in use, the official seal of the
notary public must be kept safe and secure and shall be accessible only to him or the person
duly authorized by him.

Here, respondent Atty. Belaro utterly failed to sufficiently provide any laudable explanation why
his notarial seal was found in the documents. He simply asserted in his Answer to the Letter-
Complaint that the signatures of the notary public found in the subject instruments were not
his, that he did not cause the filing of these documents to any government agencies, and that
he never employed Dioneda as his secretary. Indubitably, respondent Atty. Belaro did not
properly secure and keep his notarial seal in a safe place inaccessible to other persons so as to
ensure that nobody can use the same without his authority. Had he done so, his notarial seal
would not have been affixed to the Extrajudicial Settlement which converted the same from a

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private document into a public document. Thus, respondent Atty. Belaro has been remiss in his
duty to exercise utmost diligence in the performance of his functions as a notary public and to
comply with the mandates of law. In being careless in failing to secure and keep his notarial seal
in a safe place away from any person not authorized to use the same, respondent Atty. Belaro
committed a transgression of the Notarial Law and the CPR. The negligence of respondent Atty.
Belaro likewise extended to his reportorial duties as Notary Public. Although he appeared not
to have notarized the Deed of Absolute Sale and the Acknowledgement Receipt yet he entered
the same in his Notarial Registry Book. Had respondent Atty. Belaro been meticulous and
cautious in the performance of his duties as Notary Public, he would have noticed from the start
that he did not notarize the subject instruments and excluded the same from his Notarial
Registry Book. Ang v. Belaro, Jr., A.C. No. 12408, December 11, 2019

An affidavit of desistance executed by the complainant or the withdrawal of the complaint is

not sufficient cause to warrant the dismissal of an administrative complaint.

It remains true notwithstanding the reasons raised by the complainant as to the execution of
the affidavit or withdrawal of the complaint. The main objective of disciplinary proceedings is to
determine the fitness of a member to remain in the Bar. It is conducted for the public welfare
and the desistance of the complainant is irrelevant. What matters is whether the charge in the
complaint has been proven on the basis of the facts borne out by the record. This was
exhaustively emphasized by the Court in Loberes-Pintal v. Baylosis, citing Bautista v. Bernabe, to
wit: A case of suspension or disbarment may proceed regardless of interest or lack of interest of
the complainant. What matters is whether, on the basis of the facts borne out by the record,
the charge of deceit and grossly immoral conduct has been proven. This rule is premised on the
nature of disciplinary proceedings. A proceeding for suspension or disbarment is not a civil
action where the complainant is a plaintiff and the respondent lawyer is a defendant.
Disciplinary proceedings involve no private interest and afford no redress for private grievance.
They are undertaken and prosecuted solely for the public welfare. They are undertaken for the
purpose of preserving courts of justice from the official ministration of persons unfit to practice
in them. The attorney is called to answer to the court for his conduct as an officer of the court.
The complainant or the person who called the attention of the court to the attorney's alleged
misconduct is in no sense a party, and has generally no interest in the outcome except as all
good citizens may have in the proper administration of justice. Ang v. Belaro, Jr., A.C. No. 12408,
December 11, 2019

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It bears to stress that membership to the Bar has always been jealously guarded such that only
those who have successfully hurdled the stringent examinations, possessed and maintained
the required qualifications are allowed to enjoy the privileges appurtenant to the title.

Thus, it has been said that "[t]he title of 'attorney' is reserved to those who, having obtained the
necessary degree in the study of law and successfully taken the Bar Examinations, have been
admitted to the Integrated Bar of the Philippines and remain members thereof in good standing;
and it is they only who are authorized to practice law in this jurisdiction." "The practice of law is
a privilege burdened with conditions and is reserved only for those who meet the twin standards
of legal proficiency and morality. It is so delicately imbued with public interest that it is both a
power and a duty of this Court to control and regulate it in order to protect and promote the
public welfare." However, Atty. Rivera abused the privilege that is only personal to him when he
allowed another who has no license to practice law, to sign pleadings and to file a suit before
the court using his signature and "details." By allowing a non-lawyer to sign and submit pleadings
before the court, Atty. Rivera made a mockery of the law practice which is deeply imbued with
public interest; he totally ignored the fact that his act of filing a suit will have a corresponding
impact and effect on the society, particularly on the life and property rights of the person or
persons he wittingly involved in the litigation, in this case, Fe and Petelo. Petelo v. Rivera, A.C.
No. 10408, October 16, 2019

The preparation and signing of a pleading constitute legal work involving practice of law
which is reserved exclusively for the members of the legal profession.

Counsel may delegate the signing of a pleading to another lawyer but cannot do so in favor of
one who is not. The Code of Professional Responsibility provides: Rule 9.01 — 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. Moreover, a signature by agents of a lawyer
amounts to signing by unqualified persons, something the law strongly proscribes. Therefore,
the blanket authority respondent claims Atty. Garlitos entrusted to just anyone was void. Any
act taken pursuant to that authority was likewise void. There was no way it could have been
cured or ratified by Atty. Garlitos' subsequent acts. Petelo v. Rivera, A.C. No. 10408, October
16, 2019

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There is, thus, no question in our mind that by delegating to someone else the work that is
reserved only for lawyers, Atty. Rivera violated Rule 9.01 of Canon 9 of the Code of Professional
Responsibility.

In addition, the actuations of Atty. Rivera tended to mislead the Court. Indeed, the RTC of Makati
City was misled into believing that the complaint was filed by the real party-in-interest and that
Atty. Rivera was duly authorized to file the same. As it turned out, the RTC eventually dismissed
the complaint after it was established thru the Manifestation filed by Petelo that it was filed not
by the real party-in-interest or by the duly authorized representative. Atty. Rivera, thus, in
violation of Rule 10.01, Canon 10, committed a falsehood, or consented to the doing of any in
court; he not only misled the RTC but likewise wasted its precious time and resources. Petelo v.
Rivera, A.C. No. 10408, October 16, 2019

The directive to comply with the MCLE requirements is essential for the legal profession, as
enshrined in Bar Matter No. 850. The purpose is "to ensure that throughout [the IBP
members'] career, they keep abreast with law and jurisprudence, maintain the ethics of the
profession and enhance the standards of the practice of law."

Turla was able to secure a Certification dated August 2, 2010 from the MCLE Office that Atty.
Caringal, as of said date, had not yet complied with the requirements for MCLE II and III
compliance periods. Despite being confronted with such Certification by Turla, Atty. Caringal
continued to sign and submit pleadings and motions before various courts in several cases,
indicating therein that he was "exempt" from the MCLE requirements and referring to the
Official Receipt for his payment of the non-compliance fees. xxx A non-compliant lawyer must
pay a non-compliance fee of PhP1,000.00 and still comply with the MCLE requirements within a
sixty (60)-day period, otherwise, he/she will be listed as a delinquent IBP member after
investigation by the IBP-CBD and recommendation by the MCLE Committee. The non-
compliance fee is a mere penalty imposed on the lawyer who fails to comply with the MCLE
requirements within the compliance period and is in no way a grant of exemption from
compliance to the lawyer who thus paid. It is worthy to note that Atty. Caringal could not be
declared a delinquent member as the sixty (60)-day period for compliance did not commence
to run. There was no showing that he was ever issued and that he had actually received a Non-
Compliance Notice as required by the MCLE Implementing Rules. Turla v. Caringal, A.C. No.
11641, March 12, 2019

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BM No. 1922, issued on June 3, 2008, required the practicing members of the IBP to indicate
in all pleadings filed before the courts or quasi-judicial bodies, the number and date of issue
of their MCLE Certificate of Compliance or Certificate of Exemption, as may be applicable, for
the immediately preceding compliance period.

Prior to its amendment on January 14, 2014, BM No. 1922 imposed a stiff penalty for a practicing
lawyer's failure to indicate the details of his/her MCLE Compliance/Exemption in the pleadings
filed before the courts or quasi-judicial bodies, i.e., the dismissal of the case and expunction of
the pleadings from the records, which, in effect, ultimately penalized said lawyer's clients, too.
Atty. Caringal, in this case, not only failed to indicate the necessary MCLE details in his pleadings
and motions, but purposely stated therein the false information that he was exempted from
MCLE II and III. As he had filed the subject pleadings in 2010, prior to the amendment of BM No.
1922 on January 14, 2014, he risked the dismissal of the cases and expunction of the pleadings
and motions by the courts, to his clients' detriment. In fact, as Turla mentioned, the pleadings
which Atty. Caringal filed before the RTC of Makati City, Branch 59, in Civil Case No. 09-269, were
indeed expunged from the records per the Order dated March 4, 2013 because of the false MCLE
information he indicated therein. When Atty. Caringal indicated that he was MCLE-exempt in
the pleadings and motions he filed, although in fact he was not, he engaged in dishonest conduct
which was also disrespectful of the courts. He undoubtedly placed his clients at risk, given that
pleadings with such false information produce no legal effect and can result in the expunction
of the same. Undeniably, he did not stay true to the cause of his clients and actually violated his
duty to serve his clients with competence and diligence. Turla v. Caringal, A.C. No. 11641,
March 12, 2019

While lawyers are mandated to act with dignity and in a manner that inspires confidence to
the legal profession, their rights must still be protected just like every ordinary individual. The
legal profession and the threat of disbarment should not be used as a means to provoke
lawyers who are acting well within their rights.

The main issue in this case is whether Atty. Bensi should be disciplined for his involvement in
the June 5, 2013 altercation with the complainants over a disputed family property. The Court
observes that Atty. Bensi was in possession of the disputed property when the complainants
tried to enter and take it. Complainants were then equipped with a hammer and a flat bar to
force their way inside a locked gate of the chapel. Complainants believed that they were the
lawful owners of the property on the strength of a Partial Summary Judgment which awarded
the property to Lucille's now deceased parents. Nevertheless, even if the complainants are
indeed the lawful owners of the disputed property, they should not have taken the law into their
own hands through force. What the complainants should have done was to invoke the aid of the
proper court in lawfully taking possession of the property. In light of the foregoing, the Court

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finds that the complainants failed to establish through substantial evidence a cause for
disciplinary action against Atty. Bensi. Spouses Nocuenca v. Bensi, A.C. No. 12609, [February
10, 2020

As a rule, this Court exercises the power to disbar with great caution. Being the most severe
form of disciplinary sanction, it is imposed only for the most imperative reasons and in clear
cases of misconduct affecting the standing and moral character of the lawyer as an officer of
the court and a member of the bar.

We agree with the Investigating Commissioner's finding that the remedies which Attys. Baterina
and Besid pursued and exhausted were sanctioned by the applicable rules and were intended
solely to advance their clients' interest in the kidnapping case. Furthermore, they did not violate
Canon 11, Rule 11.03 when they filed a certiorari petition before the CA in order to assail the
issuances of the RTC. In fact, their actions are supported by Canons 17 and 19 of the CPR.
Similarly, Attys. Tiblani and Pammit who were representing Atty. Baterina in the latter's
disbarment cases were merely protecting Atty. Baterina's interests. Indeed, "[a] lawyer owes
entire devotion to the interest of his client, warmth and zeal in the maintenance and defense of
his rights and the exertion of his utmost learning and ability, to the end that nothing can be
taken or withheld from his client except in accordance with the law. He should present every
remedy or defense authorized by the law in support of his client's cause, regardless of his own
personal views. In the full discharge of his duties to his client, the lawyer should not be afraid of
the possibility that he may displease the judge or the general public." To Our mind, the
respondents' acts did not constitute as gross misconduct or a violation of the Lawyer's Oath or
the CPR. Additionally, the respondents committed none of the grounds for disbarment
enumerated in Section 27, Rule 138 of the Rules of Court. Perito v. Baterina, A.C. No. 12631,
July 8, 2020

"Lawyers should be reminded that their primary duty is to assist the courts in the
administration of justice. Any conduct [that] tends to delay, impede or obstruct the
administration of justice contravenes [this obligation]."

In engaging in forum shopping, Atty. Alentajan violated Canon 1 of the CPR which directs lawyers
to obey the laws of the land and promote respect for the law and legal processes. He also
disregarded his duty to assist in the speedy and efficient administration of justice, and the
prohibition against unduly delaying a case by misusing court processes. Regardless of the fact
that Atty. Alentajan did not act as counsel in Civil Case No. Q-05-5629, it would not exempt him
from culpability. He knowingly filed another civil case despite the finality of the judgment in Civil

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Case No. Q-05-5629 which already resolved the issue of ownership and validity of foreclosure of
mortgage of the subject property. In fact, aside from filing Civil Case No. R-QZN-13-02119-CV,
Atty. Alentajan assisted his clients in filing various cases such as, criminal complaint for violation
of Sections 1 and 36 of RA No. 7653 in relation to Sections 4 and 6 of RA No. 3765, criminal
complaint for violation of Article 302 of the RPC or robbery in an uninhabited place or a private
building and contempt against the officers of COCOLIFE which were all dismissed for lack of
merit. Villanueva v. Alentajan, A.C. No. 12161, June 8, 2020

Acts of signing and filing of pleadings for a client in criminal case months after the
promulgation of the resolution of disbarment are clear proofs that an erring lawyer practiced
law during the period of his suspension. However, considering that the Court had already
imposed upon respondent the ultimate penalty of disbarment, the penalty of additional
suspension from the practice of law can no longer be imposed upon him.

The reason is obvious: "[o]nce a lawyer is disbarred, there is no penalty that could be imposed
regarding his privilege to practice law." But while the Court can no longer impose the penalty
upon the disbarred lawyer, it can still give the corresponding penalty only for the sole purpose
of recording it in his personal file with the Office of the Bar Confidant (OBC), which should be
taken into consideration in the event that the disbarred lawyer subsequently files a petition to
lift his disbarment. In addition, the Court may also impose a fine upon a disbarred lawyer found
to have committed an offense prior to his/her disbarment as the Court does not lose its exclusive
jurisdiction over other offenses committed by a disbarred lawyer while he/she was still a
member of the Law Profession. In fact, by imposing a fine, the Court is able "to assert its
authority and competence to discipline all acts and actuations committed by the members of
the Legal Profession." Valmonte v. Quesada, Jr., A.C. No. 12487, December 4, 2019

It is well-settled that the essence of forum shopping is the filing of multiple suits involving the
same parties for the same cause of action, either simultaneously or successively, for the
purpose of obtaining a favorable judgment.

It exists when, as a result of an adverse opinion in one forum, a party seeks a favorable opinion
in another, or when he institutes two or more actions or proceedings grounded on the same
cause to increase the chances of obtaining a favorable decision. An important factor in
determining its existence is the vexation caused to the courts and the parties-litigants by the
filing of similar cases to claim substantially the same reliefs. Forum shopping exists where the
elements of litis pendentia are present or where a final judgment in one case will amount to res
judicata in another. Evidently, Atty. Teruel willfully committed forum shopping when he

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instituted two actions grounded on the same cause, even if strictly speaking, he was not included
as a "complainant" in Fr. Reyes' Complaint. This is because he prepared and filed both
administrative actions with full knowledge that they have the same cause of action and
contained nearly exactly the same allegations. Simply put, the outcome in one case would
necessarily have an effect in the other since both cases share the same cause of action and
involve the same parties. Go v. Teruel, A.C. No. 11119, November 4, 2020

The Court notes that it is not strictly the actual docketing of the administrative complaints but
the mere act of filing multiple complaints with the same cause/s of action, parties and relief/s
which constitutes a violation of the rule against forum shopping.

It is the commencement or the filing of actions involving the same parties, issue/s and relief/s
which would amount to forum shopping. There is no qualification that the pleadings should first
be accepted by the tribunal/agency or properly docketed before forum shopping could be
deemed committed. It is enough that the party concerned filed multiple actions involving the
same parties, cause/s of action, and relief/s before a court, tribunal, or agency. The intent of the
individual who files multiple complaints to secure a favorable ruling is what is being sought to
be penalized. In any case, even if Atty. Teruel's Counter-Complaint was not acted upon or
separately docketed by the IBP, the same pleading, specifically his Rejoinder to Reply and
Counter-Complaint in CBD Case No. 11-2989, was still admitted. In other words, Atty. Teruel's
Rejoinder to Reply was still considered in CBD Case No. 11-2989 even if his Counter-Complaint
has yet to be processed or acted upon. Go v. Teruel, A.C. No. 11119, November 4, 2020

The Lawyer's Oath mandates every lawyer to conduct himself/herself according to the best of
his/her knowledge and discretion, with all good fidelity as well to the courts as to his/her
clients.

Atty. Centro unfortunately departed from his sworn oath by committing the following acts: 1)
failing to file a Memorandum and even misrepresenting about filing it; 2) failing to inform
Portuguese of the RTC's Decision; 3) failing to protect Portuguese's interest against the adverse
RTC's Decision; 4) failing to inform Portuguese of the Motion for Execution, the scheduled
hearing, and the resolution granting the said motion; and 5) failing to file an Answer to the
instant Complaint. Worse, when Portuguese confronted him about the deliberate lapses
concerning the civil case, the latter merely replied that there was nothing more he could do and
that he was giving up the case for good. Portuguese, Jr. v. Centro, A.C. No. 12875, January 26,
2021

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In administrative proceedings against a lawyer, the Court, in the exercise of its disciplinary
powers, "calls upon a member of the Bar to account for his actuations as an officer of the Court
with the end in view of preserving the purity of the legal profession and the proper and honest
administration of justice by purging the profession of members who by their misconduct have
proved themselves no longer worthy to be entrusted with the duties and responsibilities
pertaining to the office of an attorney."

In this case, We note that Atty. Centro disregarded the directive for him to file his Answer to the
Complaint against him. This only goes to show Atty. Centro's indifference to lawful orders and
established processes. "His unexplained disregard of the orders issued to him by the IBP to
comment x x x revealed his irresponsibility as well as his disrespect for the IBP and its
proceedings. He thereby exposed a character flaw that should not tarnish the nobility of the
Legal Profession." Portuguese, Jr. v. Centro, A.C. No. 12875, January 26, 2021

Being a lawyer is a privilege burdened with conditions. As a member of the bar, [he] must
maintain the integrity and dignity of the legal profession by refraining from committing acts
which might diminish in any degree the confidence of the public in the fidelity, honesty and
integrity of the profession."

Atty. Centro should have informed Portuguese at the earliest opportunity that he could no
longer properly represent him and perform his functions as counsel. This way, Portuguese would
have the option to secure the services of another lawyer so that his interests would be
protected. Unfortunately, Atty. Centro did not even bother to apprise Portuguese about the
developments in the civil case or inform him of his incapacity to continue as counsel. In fine,
respondent committed transgressions not only against his client but the IBP and the Court as
well. Portuguese, Jr. v. Centro, A.C. No. 12875, January 26, 2021

The prohibition against a lawyer representing conflicting interests is rooted in his duty to
protect the interest and confidence of his clients.

A member of the bar vows in the Lawyer's Oath to conduct himself as a lawyer according to the
best of his knowledge and discretion with all good fidelity to the courts as well as to his client.
To ensure the fidelity of a lawyer to his clients, Canon 15.03 of the CPR prescribes that "[a]
lawyer shall not represent conflicting interests except by written consent of all concerned given
after a full disclosure of the facts[;]" while Canon 17 of the same Code mandates that "[a] lawyer
owes fidelity to the cause of his client and shall be mindful of the trust and confidence reposed
in him." Section 20 (e) of Rule 138 of the Rules of Court likewise enjoins a lawyer "[t]o maintain

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inviolate the confidence, and at every peril to himself, to preserve the secrets of his client x x x."
Parungao v. Lacuanan, A.C. No. 12071, March 11, 2020

A lawyer's duty to protect the interest and confidence of his client, together with the corollary
obligation not to represent interest in conflict or inconsistent with the same, extends even
beyond the end of his professional engagement with said client.

The termination of attorney-client relation provides no justification for a lawyer to represent an

interest adverse to or in conflict with that of the former client. The client's confidence once
reposed should not be divested by mere expiration of processional employment. Even after the
severance of the relation, a lawyer should not do anything which will injuriously affect his former
client in any natter in which he previously represented him nor should he disclose or use any of
the client's confidences acquired in the previous relation. In addition, "[t]he protection given to
the client is perpetual and does not cease with the termination of the litigation, nor is it affected
by the party's ceasing to employ the attorney and retaining another, or by any other change of
relation between them. It even survives the death of the client." Parungao v. Lacuanan, A.C.
No. 12071, March 11, 2020

The Court had lay down the tests by which it can be determined whether or not a conflict of
interests exists.

Rule 15.03, Canon 5 of the Code of Professional Responsibility provides: "A lawyer shall not
represent conflicting interests except by written consent of all concerned given after a full
disclosure of the facts." This prohibition is founded on principles of public policy and good taste.
In the course of a lawyer-client relationship, the lawyer learns all the facts connected with the
client's case, including the weak and strong points of the case. The nature of that relationship
is, therefore, one of trust and confidence of the highest degree. It behooves lawyers not only to
keep inviolate the client's confidence, but also to avoid the appearance of treachery and double-
dealing for only then can litigants be encouraged to entrust their secrets to their lawyers, which
is of paramount importance in the administration of justice.

In broad terms, lawyers are deemed to represent conflicting interests when, in behalf of one
client, it is their duty to contend for that which duty to another client requires them to oppose.
Developments in jurisprudence have particularized various tests to determine whether a
lawyer's conduct lies within this proscription. One test is whether a lawyer is duty-bound to fight
for an issue or claim in behalf of one client and, at the same time, to oppose that claim for the

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other client. Thus, if a lawyer's argument for one client has to be opposed by that same lawyer
in arguing for the other client, there is a violation of the rule.

Another test of inconsistency of interests is whether the acceptance of a new relation would
prevent the full discharge of the lawyer's duty of undivided fidelity and loyalty to the client or
invite suspicion of unfaithfulness or double-dealing in the performance of that duty. Still another
test is whether the lawyer would be called upon in the new relation to use against a former
client any confidential information acquired through their connection or previous employment.
Parungao v. Lacuanan, A.C. No. 12071, March 11, 2020

Of the three tests identified above, the third test — with references to "new relation," "former
client," and "previous employment" — specifically applies to a situation wherein the
professional engagement with the former client was already terminated when the lawyer
entered into a new engagement with the present client.

It bears to stress that this test explicitly requires the lawyer's use against his former client of
"confidential information acquired through their connection or previous employment."
Parungao v. Lacuanan, A.C. No. 12071, March 11, 2020

The Court further categorically declared in Palm v. Iledan, Jr. that "[a] lawyer's immutable
duty to a former client does not cover transactions that occurred beyond the lawyer's
employment with the client. The intent of the law is to impose upon the lawyer the duty to
protect the client's interests only on matters that he previously handled for the former client
and not for matters that arose after the lawyer-client relationship has terminated."

Hence, for there to be conflicting interests when a former client is involved, the following
circumstances must concur: (a) the lawyer is called upon in his present engagement to make use
against a former client confidential information which was acquired through their connection or
previous employment, and (b) the present engagement involves transactions that occurred
during the lawyer's employment with the former client and matters that the lawyer previously
handled for the said client. Parungao v. Lacuanan, A.C. No. 12071, March 11, 2020

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In contrast, when the opposing parties are both the lawyer's present clients, the prohibition
on conflicting interests is necessarily stricter and its extent broader.

As reflected in the following pronouncements of the Court in the Quiambao Case: The
proscription against representation of conflicting interests applies to a situation where the
opposing parties are present clients in the same action or in an unrelated action. It is of no
moment that the lawyer would not be called upon to contend for one client that which the
lawyer has to oppose for the other client, or that there would be no occasion to use the
confidential information acquired from one to the disadvantage of the other as the two actions
are wholly unrelated. It is enough that the opposing parties in one case, one of whom would
lose the suit, are present clients and the nature or conditions of the lawyer's respective retainers
with each of them would affect the performance of the duty of undivided fidelity to both clients.
Parungao v. Lacuanan, A.C. No. 12071, March 11, 2020

The Court has consistently held that an attorney enjoys the legal presumption that he is
innocent of the charges against him until the contrary is proved, and that as an officer of the
court, he is presumed to have performed his duties in accordance with his oath.

Burden of proof, on the other hand, is defined in Section 1 of Rule 131 as the duty of a party to
present evidence on the facts in issue necessary to establish his claim or defense by the amount
of evidence required by law. Parungao v. Lacuanan, A.C. No. 12071, March 11, 2020

Simply put, in determining whether a lawyer is guilty of violating the rules on conflict of
interest under the CPR, it is essential to determine whether: (1) "a lawyer is duty-bound to
fight for an issue or claim in behalf of one client and, at the same time, to oppose that claim
for the other client"; (2) "the acceptance of a new relation would prevent the full discharge of
a lawyer's duty of undivided fidelity and loyalty to the client or invite suspicion of
unfaithfulness or double-dealing in the performance of that duty"; and (3) "a lawyer would be
called upon in the new relation to use against a former client any confidential information
acquired through their connection or previous employment."

Under the first test, there is conflict of interest if the lawyer represents both opposing parties in
an issue or claim. Stated differently, "if a lawyer's argument for one client has to be opposed by
that same lawyer in arguing for the other client, there is a violation of the rule." The Court finds
that there was no violation under the parameters of this test. Respondents did not represent
conflicting interests — HGC's and BSCDC's interests — here. As found by the IBP, the Law Firm
did not represent BSCDC as counsel in the arbitration case. The arbitration complaint

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was signed by Atty. Ruben L. Almadro (Atty. Almadro) as BSCDC's counsel. Atty. Almadro is not
part or related to the Law Firm. On the other hand, Atty. Tagayuna merely signed as president
to verify the complaint. Further, evidence show that the Law Firm and ESP were engaged by
HGC for collection purposes only; as determined by the IBP, there is no proof that the Law Firm
handled matters that were related to the arbitration case. Also, it was established that the Law
Firm was no longer retained as counsel at the time of the filing of the arbitration case. The
Collection Retainership Agreement expired on December 31, 2011 and was never renewed,
while the arbitration case was filed in May 2012. Considering the foregoing, respondents did not
represent both opposing parties (i.e., HGC and BSCDC) in an issue or claim, particularly the
arbitration case.

For the second test, there is conflict of interest if the acceptance of a new relation or
engagement will prevent the lawyer from faithfully performing his duties to a client. The second
test is not relevant to the instant case; the factual circumstances did not include allegations of
respondents' acceptance of a new relation while being counsel of HGC that prevented them
from faithfully performing their duties to it. There is no showing that BSCDC is a new client of
the Law Firm.

The third test provides that there is conflict of interest if the lawyer, in a new relation, would be
called upon to use against a former client any confidential information he has acquired through
their connection or previous employment. This test specifically applies to situations where the
professional relationship with a former client was already terminated when the lawyer was
engaged by a new client. The Court stated that "for there to be conflicting interests when a
former client is involved, the following circumstances must concur: (a) the lawyer is called upon
in his present engagement to make use against a former client confidential information[,] which
was acquired through their connection or previous employment[;] and (b) the present
engagement involves transactions that occurred during the lawyer's employment with the
former client and matters that the lawyer previously handled for the said client." Related to this,
proof must be adduced to show that the former client intended the information to be
confidential; mere relation between attorney and client does not create a presumption of
confidentiality. Indeed, the professional relationship between the Law Firm and HGC expired on
December 31, 2011. However, there is no proof that the Law Firm, in a new matter, used against
HGC confidential information acquired from their previous relation. HGC merely made
allegations that respondents represented BSCDC while being engaged as its counsel. To
reiterate, the subject of arbitration are matters not handled by the Law Firm; the Law Firm was
engaged for collection purposes only — this is clear in the Collection Retainership Agreement as
adduced in evidence. In any event, there is no new relation to speak of as BSCDC is not a client
of the Law Firm. Home Guaranty Corp. v. Tagayuna, A.C. No. 13131, February 23, 2022

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Professional rules impose limits on a lawyer's zeal and hedge it with necessary restrictions and
qualifications.

In this case, the Court notes that Atty. Plata did not deny that he had filed several civil, criminal
and administrative cases against the opposing parties and their counsels. In his Answer to the
administrative complaint, Atty. Plata justifies the various pending suits filed by him and his
client, Eustaquio, as proof of the truth and veracity of the allegations against Pagdanganan and
his co-respondents. However, upon examination of the records, it becomes apparent that these
suits are mere harassing tactics against Pagdanganan, his co-respondents and their counsel. The
Court is mindful of Atty. Plata's duty to defend his client's cause with utmost zeal. However,
professional rules, as above-quoted, impose limits on a lawyer's zeal and hedge it with necessary
restrictions and qualifications. Atty. Plata's filing of several cases against the adverse parties and
their counsel lays bare his intent to repress the opposing counsel from exerting utmost effort in
protecting his clients' interests. The filing of several groundless suits and the reservation of filing
another perjury suit in the future despite the pendency of another perjury case reveal Atty.
Plata's gross indiscretion as a colleague in the legal profession, in blatant violation of his oath
and duties as a lawyer. Pagdanganan v. Plata, A.C. No. 12701, February 26, 2020

Once a lawyer agrees to represent a client, he/she is duty-bound to exert his/her best effort
and to serve the latter with utmost diligence and competence. A lawyer owes fidelity to his/her
client's cause and must always be mindful of the trust and confidence reposed upon him/her.
A lawyer's neglect of a legal matter entrusted to him/her by his/her client constitutes
inexcusable negligence for which he/she must be held administratively liable.

In this case, Atty. Sagario breached his duties to his client when he failed to exercise due
diligence in handling the annulment case of complainant. In fact, to the detriment of
complainant, he failed to render any legal service to her despite receipt of fees in the total
amount of PhP 57,000.00. This constitutes a clear violation of Rule 18.03, Canon 18 of the CPR.
Atty. Sagario also violated Canon 16, Rules 16.01 and 16.03, and Canon 17 when he failed to
return the amount of PhP 57,000.00 upon complainant's demand. Francia v. Sagario, A.C. No.
10938, October 8, 2019

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The highly fiduciary nature of an attorney-client relationship imposes upon the lawyer the duty
to account for the money received from his/her client. A lawyer's failure to return upon
demand the money he/she received from his/her client gives rise to the presumption that
he/she has appropriated the same for his/her own use.

An attorney-client relationship requires utmost good faith, loyalty, and fidelity on the part of
the lawyer. In this case, Atty. Sagario clearly fell short of the demands required of him as a
member of the Bar. Moreover, Atty. Sagario did not bother to submit his response to the
complaint before the MeTC in the small claims action filed against him. To make matters worse,
Atty. Sagario did not even appear during the scheduled mandatory conference or file any
responsive pleading before the IBP despite due notice. Atty. Sagario's failure or refusal to answer
the complaint against him and to appear at the mandatory hearings before the MeTC and the
IBP are manifestations of his stubborn, disobedient, and disrespectful attitude toward lawful
orders of the court and illustrate his willful disregard for his oath of office. Francia v. Sagario,
A.C. No. 10938, October 8, 2019

Disciplinary proceedings are reserved only for those belonging in the legal profession. Clearly,
respondent is not and was never a member of the bar. Hence, the penalty of disbarment is not
available to him.

It is only fitting to stress once again that the practice of law is not a right but a privilege bestowed
by the State only on those who possess and continue to possess, the qualifications required by
law for the conferment of such privilege. AA Total Learning Center for Young Achievers, Inc. v.
Caronan, A.C. No. 12418, March 10, 2020

Disciplinary proceedings against lawyers are sui generis.

We also take this opportunity to reiterate that administrative cases against lawyers belong to a
class of their own, distinct from and may proceed independently of civil and criminal cases.
There is no prejudicial question not proscription that will prevent it from proceeding. Double
jeopardy or in pari delicto are also not available as defenses as to bar the disciplinary
proceedings against an erring lawyer. It should be noted that it can be initiated motu proprio by
the Supreme Court or the IBP and even without a complaint and can proceed regardless of lack
of interest of the complainants, if the facts proven so warrant. AA Total Learning Center for
Young Achievers, Inc. v. Caronan, A.C. No. 12418, March 10, 2020

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Disciplinary proceeding againts lawyers are neither purely civil nor purely criminal, they do
not involve a trial of an action or a suit, but are rather investigations by the Court into the
conduct of one of its officers.

Not being intended to inflict punishment, they are in no sense a criminal prosecution.
Accordingly, there is neither a plaintiff nor a prosecutor therein. Public interest is their primary
objective, and the real question for determination is whether or not the attorney is still a fit
person to be allowed the privileges as such. Hence, in the exercise of its disciplinary powers, the
Court merely calls upon a member of the Bar to account for his actuations as an officer of the
Court with the end in view of preserving the purity of the legal profession and the proper and
honest administration of justice by purging the profession of members who by their misconduct
have proven themselves no longer worthy to be entrusted with the duties and responsibilities
pertaining to the office of an attorney. All told, the privilege to practice the legal profession is
not a permanent right and may be taken away if one falls short of the requirements imposed by
law. AA Total Learning Center for Young Achievers, Inc. v. Caronan, A.C. No. 12418, March 10,
2020

Death of a respondent public servant in an administrative case before its final resolution is a
cause for its dismissal.

Otherwise stated, the non-dismissal of a pending administrative case in view of the death of the
respondent public servant is a transgression of his or her Constitutional rights to due process
and presumption of innocence. Simply put, upon the death of the respondent public servant
awaiting final judgment, the dismissal of the administrative case against him/her should
necessarily follow. xxx [I]f viewed from the Constitutional lens, particularly that the respondent
in the administrative case, similar to the accused in criminal cases, likewise enjoys the rights to
presumption of innocence and due process, the Court now deems the dismissal of the instant
administrative case proper based on the following grounds: (1) pending final judgment in the
administrative case, the respondent enjoys the right to be presumed innocent; (2) the rule in
criminal cases that death of an accused extinguishes personal criminal liability as well as
pecuniary penalties arising from the felony when the death occurs before final judgment should
likewise be applied in administrative cases; (3) the essence of due process necessitates the
dismissal of the administrative case; and (4) humanitarian reasons also call for the grant of death
and survivorship benefits in favor of the heirs. Re: Investigation Report on the Alleged Extortion
Activities of Presiding Judge Godofredo B. Abul, Jr., Branch 4, Regional Trial Court, Butuan City,
Agusan Del Norte, A.M. No. RTJ-17-2486 (Resolution), September 8, 2020

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