Director of Religious affairs vs bayot

74 Phil 579 – Legal Ethics – Malpractice

In June 1943, Bayot advertised in a newspaper that he helps people in securing marriage
licenses; that he does so avoiding delays and publicity; that he also makes marriage
arrangements; that legal consultations are free for the poor; and that everything is confidential.
The Director of Religious Affairs took notice of the ad and so he sued Bayot for Malpractice.

Bayot initially denied having published the advertisement. But later, he admitted the same and
asked for the court’s mercy as he promised to never repeat the act again.

ISSUE: Whether or not Bayot is guilty of Malpractice.

HELD: Yes. Section 25 of Rule 127 expressly provides among other things that “the practice of
soliciting cases at law for the purpose of gain, either personally or thru paid agents or brokers,
constitutes malpractice.” The advertisement he caused to be published is a brazen solicitation
of business from the public. .” It is highly unethical for an attorney to advertise his talents or skill
as a merchant advertises his wares. The Supreme Court again emphasized that best
advertisement for a lawyer is the establishment of a well-merited reputation for professional
capacity and fidelity to trust. But because of Bayot’s plea for leniency and his promise and the
fact that he did not earn any case by reason of the ad, the Supreme Court merely reprimanded
him