DALLONG-GALICINAO VS.

CASTRO
A.C. No. 6396 | October 25, 2005

FACTS:
Complainant Atty. Rosalie Dallong-Galicinao filed a complaint against respondent Atty. Virgil
Castro for unprofessional conduct. It was alleged that respondent came to inquire about the transfer of
records of a case even when he did not yet enter his appearance as counsel thereof. He was told that the
records were not yet transmitted since a certified copy of the Court of Appeals decision ordering the
remand to MCTC was not yet presented. Respondent reacted angrily and hurled invectives at the
complainant. Hence, the complaint was filed. The respondent later asked for forgiveness which the
complainant accepted.

ISSUE:
Did the acts of respondent violate Canon 8? Yes.

RULING:
Yes. The respondent acted in violation of Canon 8, Rules 8.01, 8.02, and 7.03. Respondent acted rudely
towards an officer of the court. He raised his voice at the clerk of court, and uttered at her the most vulgar
of invectives. Not only was it ill-mannered but also unbecoming considering that he did all these to a
woman and in front of her subordinates. A lawyer shall conduct himself with courtesy, fairness and
candor toward his professional colleagues, and shall avoid harassing tactics against opposing counsel
(Canon 8). A lawyer shall not, in his professional dealings, use language which is abusive,
offensive, or otherwise improper (Rule 8.01). Lawyers are duty bound to uphold the dignity of the legal
profession. They must act honorably, fairly and candidly towards each other and otherwise conduct
themselves with reproach at all times. Nonetheless, the penalty to be imposed should be tempered down
owing to the fact that respondent had apologized, which the complainant accepted. Hence, Atty. Castro
was fined in the amount of PhP 10,000.00.