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HON.

MARIBETH RODRIGUEZ-MANAHAN, Presiding Judge, Municipal Trial Court, San Mateo,


Rizal, Complainant,
vs.
ATTY. RODOLFO FLORES, Respondent
A.C. No. 8954, November 13, 2013

Facts: Attorney Rodolfo Flores (Atty. Flores) was the defense counsel in a civil case (Civil Case No. 1863)
where Marsha Aranas was the plaintiff and Arnold Balmores was the defendant. The case was heard before
the Municipal Trial Court of San Mateo, Rizal, with Judge Maribeth Rodriguez-Manahan presiding. During
the proceedings, Judge Manahan issued an order voluntarily inhibiting herself from the case due to unethical
conduct and misconduct exhibited by Atty. Flores. She referred the matter to the Bar Discipline Committee
and the Supreme Court for investigation and appropriate action. The Office of the Bar Confidant treated
Judge Manahan's statements as a formal administrative complaint against Atty. Flores, and it was designated
as A.C. No. 8954. The case was subsequently referred to an investigating judge, Josephine Zarate
Fernandez, for further investigation, reporting, and recommendation. Investigating Judge Fernandez outlined
the background of the case, which involved a complaint for damages filed in the Municipal Trial Court.
Atty. Flores, representing the defendant, failed to comply with court orders and did not provide proof of
Mandatory Continuing Legal Education (MCLE) compliance. He also used inappropriate language in his
court filings. As a result, the investigating judge recommended a one-year suspension of Atty. Flores from
practicing law. The Office of the Bar Confidant adopted the findings and recommendations of the
investigating judge.
Issue: Whether respondent should be suspended from practice of law for using intemperate language in his
pleadings
Ruling: NO. Although there is no doubt that Atty. Flores failed to obey the trial court's order to submit
proof of his MCLE compliance notwithstanding the several opportunities given him. Atty. Flores also
employed intemperate language in his pleadings. As an officer of the court, Atty. Flores is expected to be
circumspect in his language. However, the court found the recommended penalty too harsh and not
commensurate with the infractions committed by the respondent. It appears that this is the first infraction
committed by respondent. Also, the court is not prepared to impose on the respondent the penalty of one-
year suspension for humanitarian reasons. Respondent manifested before this Court that he has been in the
practice of law for half a century. Thus, he is already in his twilight years. Considering the foregoing, the
court deem it proper to fine respondent and to remind him to be more circumspect in his acts and to obey
and respect court processes.

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