Canon 12, Rule: 12.

04:

GR No. 133090, January 19, 2001

Rexie Efren A. Bugaring and Royal Bechtel Builders Inc. vs. Hon. Dolores Espaol

Facts:

Atty. Rexie Efren A. Bugaring was counsel for Royal Bechtel Builders against Spouses Luis and Beatriz
Alvaran on a case for annulment Certificates of Title, Specific Performance and Damages with Prayer for
Preliminary Injunction or Temporary Restraining Order.

In one of the hearings, he was cited for contempt for allegedly bringing an assistant in court to
document the hearing on video tape and being disrespectful to the court.

That while Atty. Concepcion, a respondent called on his lawyer, Atty. Barzaga to proceed on behalf of his
client, Atty. Bugaring insisted that he be allowed to present his documentary evidence. He would then
interrupt the court by insisting that he be allowed to present his evidence. The Court told him a few
times to listen and yet he would speak up, often in a sarcastic manner anytime he feels like. He also
mentioned about he is more rather knowledgeable on the rules of Court. He also accused the Judge of
being antagonistic towards his client.

Held:

Atty. Bugaring was cited for contempt, sentenced to three days in jail with a fine of P 3,000. However,
appellate court ordered that P 1,000 be returned as it exceeds the P 2,000 limit.

Ratio:

The Court agrees with the appellate court. It contends that a lawyer should not be carried away in
espousing his client’s cause. He should not forget that he is an officer of the court, bound to extend
every effort and placed under duty, to assist in the speedy and efficient administration of justice
pursuant to Canon 12 of the Code of Professional Responsibility. He should not therefore misuse the
rules of procedure to defeat the ends of justice.

Lawyers should be reminded that their primary duty is to assist the courts in the administration of
justice. Any conduct which tends to delay, impede or obstruct the administration of justice contravenes
such lawyer’s duty.