LEbar 2019

UNIVERSITY OF SAN JOSE-RECOLETOS
SCHOOL OF LAW
FOR 2019 JOSENIAN BAR EXAMINEES
_____________________________________________________
LEGAL ETHICS CASE DIGEST

Prepared by: Atty. Romeo A. Reyes, Jr.
Buntag vs. Atty. Toledo, AC#12125, 2/11/2019
Buntag and his co-complainants were represented by Toledo in

several criminal cases. They claimed that he kept asking for money
despite knowing that they were indigents. This supposedly forced
them into indebtedness after loans from neighbors and high-interest-
charging institutions. COMPLAINT DISMISSED. He could not be
administratively liable based on mere general accusations without
proof. Save for their bare allegations of impropriety and violation of
the Oath, they did not attach records or any evidence to substantiate
their complaint. They did not say how much he demanded from them.
No payment receipts were attached to support their claim of
unreasonable demand for money. Receipts from financial institutions
could have show that his unreasonable demand caused them to
borrow money with high interest rates. They were allegedly forced to
sign documents and yet the same were not annexed to the complaint
to show the Court what these were. If he forced them to lie during
hearings and cross-examinations, the stenographic notes would
have shown the statements they wanted to dispute.
Buntag vs. Atty. Toledo, AC#12125, 2/11/2019
Buntag and his co-complainants were represented by Toledo in

several criminal cases. They claimed that he kept asking for money
despite knowing that they were indigents. This supposedly forced
them into indebtedness due to loans from neighbors and high-
interest-charging institutions. On the other hand, the affidavit of two
witnesses confirmed his pro bono work for complainants.
COMPLAINT DISMISSED. It was laudable for him not to limit his legal
assistance only to those who could afford his services and that he
generously provided legal services to everyone who asked for help.
Yet, his failure to put in writing his contractual agreements with his
clients, paying or not, added to the confusion on the obligations and
expectation of each party in their attorney-client relationship. A
retainer or written agreement between a lawyer and the client lists
the lawyer’s scope of services to be offered and governs the
relationship between the parties. Without a written agreement, it
would be difficult to ascertain what the parties committed to. A party
may be emboldened to make baseless demands from the other party,
presenting his or her own interpretation of their verbal agreement.
Concerned Students of Western Mindanao State University vs. Atty.

Esguerra, AC#10656, 4/3/2019
Law professor Esguerra was accused of sexually harassing or

raping Salilig who was a first year law student working as his part-
time secretary. The unsigned letter complaint was purportedly made
by Complainants through Atty. Bernardo. The latter who was also a
WMSU law professor wrote the Court that she did not represent any
student group in any case against Esguerra and that she did not file
in Salilig’s behalf against Esguerra. COMPLAINT DISMISSED. An
anonymous complaint is always received with great caution as it
originates from an unknown author. A complaint of such sort does
not always justify outright dismissal for being baseless or unfounded
for such a complaint may be easily verified and may, without much
difficulty, be substantiated and established by other competent
evidence. Here, there was total absence of any competent evidence
to substantiate and establish the allegations of the unsigned letter-
complaint.
Concerned Students of Western Mindanao State University vs. Atty.

Esguerra, AC#10656, 4/3/2019
Law professor Esguerra was accused of sexually harassing or

raping Salilig who was a first year law student working as his part-
time secretary. The unsigned letter complaint was purportedly made
by Complainants through Atty. Bernardo. The latter who was also a
WMSU law professor wrote the Court that she did not represent any
student group in any case against Esguerra and that she did not file
in Salilig’s behalf against Esguerra. COMPLAINT DISMISSED. The
Court’s duty to Bar members is not limited to administering
discipline to those culpable of misconduct but also to protecting the
reputation of those frivolously or maliciously charged. The Court will
not shirk from its responsibility to mete out the proper disciplinary
punishment to lawyers who have failed to live up to their sworn
duties. However, it will not hesitate to extend its protective arm to
those the accusation against whom is not indubitably proven. For a
lawyer’s good name is, in the ultimate analysis, his most important
possession.
Sorensen vs. Atty. Pozon, AC#11334, 1/7/2019
Sorensen paid Pozon P72,000 to reconstitute a title, petition for

issuance of owner’s copy for a lot and secure titles for two others.
She complained that he neglected her cases or at least to update on
his progress. He explained that the petition for issuance of new
owner’s copy was difficult since an aggrieved party appeared and
even filed charges against him and Sorensen. In fact, Sorensen had
to amicably settle and forego the petition. He claimed that the delay
in securing titles was her fault since she refused to pay and present
a witness to prove her possession. SUSPENDED. He neglected the
legal matters entrusted to him. He even failed to at least inform her
of the progress of the cases. His inaction violated Rules 18.03 and
18.04. He failed to safeguard her interests after the retainer
commenced. Mere acceptance of her money without fulfilling his
duties as a lawyer indicated lack of integrity and propriety.
Sps. Frias vs. Atty. Abao, AC#12467, 4/10/2019
Sps. Frias loaned P340,000 from Sps. Arbiz for their daughter’s
heart treatment. In lieu of a mortgage, a 20-year property lease
secured the P340,000 loan Sps. Frias loaned from Sps. Arbiz. In
1995, Sps. Frias left for Cotabato. They learned in 2005 that the Arbiz
heirs had taken over the leased property. They demanded for said
heirs to vacate when they returned to Capiz in 2015. They sued to
eject the heirs who refused to leave. The heirs alleged in their
answer that their parents bought the land from Sps. Frias. To prove
said sale, they attached a deed of sale notarized by Abao. Sps. Frias
argued that it was impossible for them to sell to anybody since they
were then in Mindanao. The Clerk of Court certified that the subject
deed did not exist and that Abao was not a licensed notary.
SUSPENDED WITH PERMANENT BAN AS A NOTARY. She performed
notarial acts on the subject deed knowing full well that she had no
valid commission as sufficiently proven by the COC certificate.
Commission either means grant of authority or the written evidence
of authority. A lawyer is unauthorized to perform any notarial act
without a commission. Abao misrepresented in the deed that she
was a notary and further committed a form of falsehood which is
anathema to the Oath. Her misdeed ran afoul of her duties and
responsibilities both as a lawyer and a notary. By performing notarial
acts without the necessary commission from the court, she violated
not only her oath to obey the laws, particularly the Notarial Practice
Rules, but also Canon 1 and 7 which proscribes all lawyers from
engaging in unlawful, dishonest, immoral or deceitful conduct and
directs them to always uphold the profession’s integrity and dignity.
Escobar vs. Atty. Mercado, AC#11141, 8/7/2019
Escobar left her relatives Sam and Nancy in-charge of her 4-door
apartment while she went to America. Without her knowledge and
consent, Nancy used the property for a P2-million loan with Manila
Credit Corp. (MCC). She mispresented herself as Escobar and
signed a promissory note and mortgage contract. Mercado notarized
these documents relying only on a “cedula” Nancy submitted as
proof of identity. The property was foreclosed, Escobar’s title was
cancelled and MCC secured a new title. SUSPENDED, COMMISSION
REVOKED WITH 1-YEAR BAN AS NOTARY. As a notary, he failed to
comply with the Rules when he notarized the promissory note and
real estate mortgage without requiring an identification document
with photograph and signature. There was also no credible witness
who was personally known to him and Escobar who could, under
oath or affirmation, identify the affiant or signatory of the documents
for him to verify the genuineness of the acknowledging party’s
signature.
Escobar vs. Atty. Mercado, AC#11141, 8/7/2019

Escobar left her relatives Sam and Nancy in-charge of her 4-door
apartment while she went to America. Without her knowledge and
consent, Nancy used the property for a P2-million loan with Manila
Credit Corp. (MCC). She misrepresented herself as Escobar and
signed a promissory note and mortgage contract which Mercado
notarized relying only on a “cedula” Nancy submitted as proof of
identity. The property was foreclosed, Escobar’s title was cancelled
and MCC secured a new title. SUSPENDED, COMMISSION REVOKED
WITH 1-YEAR BAN AS NOTARY. He should have exercise utmost
diligence in ascertaining Nancy’s true identity considering that the
nature of the loan documents affected Escobar’s title. Reliance on
the “cedula” could not be accepted as it did not minutely comply with
what the Rules required. His failure to properly perform his duty as a
notary resulted in Escobar’s damage as a new title was issued to
MCC based on the documents he notarized. Such title unduly
prejudiced her rights over the property. His negligence degraded
the function of notarization and diminished public confidence on
notarial documents. For having violated the Notarial Rules, he also
failed to adhere to Canon 1. He violated Rule 1.01.
Sps. Asuncion vs. Atty. Bassig, AC#11830, 7/30/2019
Bassig, on Cabangon’s behalf, filed a complaint to annul a title. Sps.

Asuncion intervened in said complaint and later filed a disbarment
complaint alleging that Cabangon died two years before annulment
case was filed as proven by his death certificate. Bassig attended
the CBD hearing but did not file his answer, brief or position paper.
An IBP resolution recommended his 2-year suspension. He moved
for reconsideration claiming that Cabangon’s agent engaged his
services, submitted to him the verification signed and notarized and
that this agent concealed Cabangaon’s death. SUSPENDED. A
lawyer owes the duty of utmost honesty and integrity to the public
and the Court. Bassig filed a complaint that was false in a critically
material aspect – the plaintiff’s status. The mere act of filing such a
complaint, alongside the proven deceased status of its purported
plaintiff, showed either Bassig’s ill-intent on one hand, or appalling
incompetence on the other, neither of which are excusable under the
circumstances.
Sps. Asuncion vs. Atty. Bassig, AC#11830, 7/30/2019
Bassig, on Cabangon’s behalf, filed a complaint to annul a title. Sps.

Asuncion intervened in said complaint and later filed a disbarment
complaint alleging that Cabangon died two years before annulment
case was filed as proven by his death certificate. Bassig attended
the CBD hearing but did not file his answer, brief or position paper.
An IBP resolution recommended his 2-year suspension. He moved
for reconsideration claiming that Cabangon’s agent engaged his
services, submitted to him the verification signed and notarized and
that this agent concealed Cabangaon’s death. SUSPENDED. His
bare denial of prior knowledge of Cabangon’s status during the
complaint’s preparation and filing, on the pretext that he only met the
agent aggravated his stance. His defensive claims, notwithstanding
their lack of proof, indicated his gross negligence in relying on a
representation of agency by a client without so much as the
requirement of a written letter of authority or a similar document to
verify the client’s identity. Even assuming his defense that he merely
relied on this supposed agent’s representations, nothing on record
showed that Bassig addressed this mistake in court after Sps.
Asuncion manifested that Cabangon already died prior to the filing of
the complaint.
Pacificar vs. Atty. Real, AC#9022, 6/10/2019
Jhonna wanted to sell a lot from her mother Juvy’s estate. Real
advised her to transfer the title to her name and settle Juvy’s estate.
She heeded his advice and paid him P155,000. She asked for an
update seven months later. He said he needed more time. She
learned from the Register of Deeds that he did not transact anything.
No petition to issue owner’s duplicate copy of lost title was also filed
in court. He ignored her demand for a refund. ORDERED TO RETURN
P75,000. The remaining P80,000 was for services already rendered
based on quantum meruit. He failed to return her money despite
demands. A lawyer must render an accounting to the client showing
that the money was spent for the intended purpose. If not used
accordingly, the money must be returned immediately to the client. A
lawyer’s failure to return client’s money despite repeated demands
violates the trust reposed on him and shows lack of integrity.
Dimaculangan vs. Attys. Jurado & Sta. Ana, AC#12359, 4/8/2019
Dimaculangan was talking to Jurado inside the courtroom waiting for

cases to be reset. Sta. Ana arrived and angrily shouted at her, “ I
don’t like what you did Girlie, Nakadalawa ka na … imagine you will
ask for a resetting tapos dadating kayo. Papano kung hindi kami
dumating, then you will camp will move that the cross examination
be waived?” He was referring to the other case where they were
opposing counsels. He scolded her for filing a motion despite the
pending certiorari petition. She tried to explain that the motion and
petition had different issue but he threatened to pursue the
administrative case against her co-counsel if her client did not drop
the case. She alleged that his public confrontation surprised and
humiliated her. REPRIMANDED. His remarks against her with other
lawyers present exhibited unprofessional conduct. Her actions may
have frustrated him but that was no excuse for him to treat opposing
counsel with courtesy, dignity and civility. His criticism was uncalled
for since she was only doing her legal duty of protecting a client. His
fault-finding remarks betrayed lack of understanding of the lawyer’s
duties to the client. He violated Rule 8.01. Lawyers have certain
obligations to each other as a result of Bar membership including
observance of honorable, candid and courteous dealings with other
lawyers.
Sevilla vs. Atty. Millo, AC#10697, 3/25/2019
Sevilla was the publisher of the provincial newspaper Pampango

Footprints. He sent a P33,120-bill to Sps. Avelino for their auction
sale notice publication. Their lawyer Millo replied that they refused to
pay the shocking and exorbitant bill. He made good on his threat to
write the Executive Judge to disqualify Pampango. While Sevilla’s
disbarment complaint was pending, Sps. Avelino negotiated for a
50% discount on the publication fee. Millo intervened and forbade
them from paying. Sevilla called Millo but the latter shouted – “I am
busy I don’t want to talk to you!” SUSPENDED. He failed
expectations despite his avowed duties as a court officer. He did not
initiate settlement of Sevilla’s publication fees. He disagreed with the
bill, chose not to pay and promptly referred it to the Executive Judge
instead of negotiating and discussing it with Sevilla. His obstinate
refusal to settle ended in forbidding his clients to pay the reduced
fee which they themselves secured. He shouted at, and ignored
Sevilla when the latter called to settle. His acts violated Rule 1.04,
Canon 1 and prejudiced his clients. Foreclosing was not completed
since Sevilla neither issued an affidavit of publication nor gave
copies of the issues where the auction notice was printed. Lawyers
owe fidelity to their client’s cause. They are expected to serve the
client with competence and diligence, use every honorable means to
defend the client’s cause and secure what is due them. Professional
rules set a limit on a lawyer’s zeal and hedge it with necessary
qualifications and restrictions like Rule 1.04.
Bakidol vs. Atty. Bilog, AC#11174, 6/10/2019
Norma entrusted her Baguio house and lot to her siste Mary since
she lived in Canada. She came home only to learn that the property’s
tax declaration had been transferred to Mary’s name using a waiver
of rights notarized by Bilog. She denied signing any waiver or
appearing before Bilog since she was abroad. He explained that a
certain “Norma” appeared before him with an expired passport as
proof of identity. He insisted that his functions as a notary were
merely ministerial. SUSPENDED, COMMISSION REVOKED WITH 2-
YEAR PROHIBITION AS A NOTARY. Sec. 2(b), Rule IV, Notarial Rules
states that a person shall not perform a notarial act if the person
involved as a signatory is not in the notary’s presence personally at
the time of the notarization and is not personally known to the notary
or identified by him through competent evidence of identity defined
by the rules. The notary must require the presence of the very
person executing the document before he notarizes it. He certifies
that it was the same person who executed and personally appeared
before him to attest to the document’s contents and truth. The
parties’ required presence enables the notary to verify the
genuineness of the affiants’ signatures. Notaries must observe the
basic requirements in performing their duties with utmost care lest
public confidence in the integrity of this form of conveyance would
be undermined. Bilog’s failure to perform his duty as a notary
undermined the notary’s integrity and degraded the function of
notarization. He was liable for such negligence, not only as a notary
but also as a lawyer.
Iglesia vs. Atty. Monsanto, AC#10597, 7/3/2019
Complainants were three police officers charged with multiple

murder and frustrated murder before the fiscal’s office. They filed
criminal and administrative cases against NBI agent Monsanto for
introducing or offering fabricated evidence in the criminal
investigations against them. DISBARMENT CASE DISMISSED.
Complainants failed to adduce any authoritative finding by any
government agency or tribunal indicating that evidence proferred
against them were fabricated despite their simultaneous use of at
least 3 platforms or stages to explain their side – the CBD, fiscal’s
office and the Ombudsman. Their conclusion that such evidence was
fabricated remained unsubstantiated. There was only their word for
it. They even failed to indicate what the Ombudsman had found vis-à-
vis the supposed “fabricated” evidence.
Wilson vs. Atty. Lastimosa, AC#11153, 6/19/2019
Elsa sued Claude for legal separation. He in turn petitioned to nullify

their marriage. Both cases were assigned to the same RTC. Elsa
gave Lastimosa documents and information relative to her legal
separation case. Lastimosa entered her appearance for Claude in
the two cases. Elsa cited conflict of interest and moved to disqualify
Lastimosa from representing Claude. SUSPENDED. Lawyers are
duty-bound to maintain undivided allegiance to their clients and to
avoid conflict of interest. Such conflict arises when a lawyer
discharges inconsistent duties or represents two or more opposing
parties’ inconsistent interests. This means that a lawyer may not act
as counsel for one client whose interest conflicts with that of another
present or previous client. A lawyer would not have obtained
information from a former client were it not for the trust and
confidence the client bestowed upon the lawyer. Moreover, it is
impossible to identify and erase such information before suing the
former client on a new one’s behalf. Such prohibition applies
whether the former and present clients are opposing parties in the
same case, a related cause or even completely unrelated case.
Pacificar vs. Atty. Real, AC#9022, 6/10/2019
Jhonna wanted to sell a lot from the estate of her mother Juvy. She
heeded Real’s advise and paid him P155,000 to transfer the title to
her name first and to settle Juvy’s estate. She asked for an update
seven months later. He said he needed more time. She later learned
from the Register of Deeds that he did not transact anything. No
petition for issuance of owner’s copy of lost title was also filed. He
ignored her demand for a refund. SUSPENDED. He did preparatory
works but failed to accomplish any task he was engaged to do. He
was negligent in performing his undertaking. A lawyer is duty-bound
to serve the client with competence. He must attend to the client’s
cause with diligence, care and devotions once he takes up such
cause whether for a fee or for free. He owes fidelity to such cause
and must always be mindful of the trust and confidence reposed
upon him. Real’s liability is tempered since he already made
preparatory works relative to his engagement, discovered issues
relative to the estate that complicated the matter referred to him and
only nine months had passed from when he was paid to the
complaint’s filing.
Huang vs. Atty. Zambrano, AC#12460, 3/26/2019
Zambrano told Huang that the respondents in the estafa cases had
offered to pay P250,000. Huang accepted the offer and suggested
for direct payment into his account or for his friend to personally
collect it. Zambrano insisted that the money go through him and
actually accepted the payment. When Huang asked for the money,
Zambrano said that the estafa case had to be dismissed first. Huang
kept asking for two months. Zambrano gave excuses, such as, no
formal dismissal yet, his busy schedule or he had family or personal
issues. Realizing that demand was futile, Huang filed a disbarment
complaint. Only Zambrano’s counsel appeared in one CBD hearing.
No answer or brief was filed. DISBARRED AND ORDERED TO
RETURN THE MONEY WITH 6% INTEREST. His reasons for non-
remittance were highly dubious, if not shallow and baseless. No law
or jurisprudence requires that the case be formally dismissed before
the lawyer yields possession of his client’s money. In advising Huang
of the same, Zambrano acted deceitfully and willfully misled and
abused his client’s trust and confidence in violation of Rule 1.01. His
alleged added excuses of heavy workload and family problems were
also highly doubtful. Even if true, they did not absolve him from
complying with his professional obligations as a lawyer. He did not
need much time or effort to transfer the money to Huang with the
different remote and online fund transfer options available.
Turla vs. Atty. Caringal, AC#11641, 3/12/2019
Turla filed a petition with the RTC alleging that Caringal had no 2 nd
and 3rd MCLE Compliance. An MCLE Office certification confirmed
the charge. Caringal indicated in his pleadings and motions a receipt
for MCLE exemption but said receipt was actually for MCLE non-
compliance fee payment. SUSPENDED. He was disrespectful and
dishonest to the Court when he indicated in his pleadings and
motions that he was MCLE exempt. BM#850 enshrines compliance
with the MCLE requirements as essential for the profession to ensure
that lawyers, throughout their careers, keep abreast with law and
jurisprudence, maintain the profession’s ethics and enhance the
standards of law practice. Rule 13, BM#850 states that as a
consequence of a lawyer’s non-compliance with the MCLE
requirements within the compliance period, he must pay a P1,000
non-compliance fee but, within a 60-day period, must still comply
with the MCLE requirements. Otherwise, he will be listed as a
delinquent IBP member after the IBP-CBD investigation and the
MCLE Committee’s recommendation. The non-compliance fee is not
a grant of exemption from compliance to the paying lawyer. It is
merely a penalty imposed for failure to comply with the requirements
within the compliance period.
Turla vs. Atty. Caringal, AC#11641, 3/12/2019
Turla filed a petition with the RTC alleging that Caringal had no 2 nd
and 3rd MCLE Compliance. An MCLE Office certification confirmed
the charge. Caringal indicated in his pleadings and motions a receipt
for MCLE exemption but said receipt was actually for MCLE non-
compliance fee payment. SUSPENDED. He could not be declared a
delinquent member as the 60-day compliance period did not start to
run. There was no proof that he was ever issued, and that he actually
received, a Non-Compliance Notice as required by the MCLE
Implementing Rules. Also, he had already complied with the MCLE
requisites for the 2nd and 3rd periods, albeit belatedly. Still, he
violated his sworn oath as a lawyer to do no falsehood as well as
Canons 1, Rule 1.01, Canon 10, Rule 10.01, Canon 17 and Canon 18.
He knowingly and willfully misrepresented in the pleadings he signed
and submitted to courts that he was exempted from MCLE II and III.
Angeles vs. Atty. Lina-ac, AC#12063, 1/8/2019
Angeles paid Lina-ac P50,000 to annul her marriage. After he gave

her a court-stamped “received” copy, she asked him to correct an
error in the petition. She asked for a copy of the rectified petition but
he simply gave an excuse. She got fed up and demanded a refund.
She learned from the court that no petition was filed. They agreed to
end their relations with him promising to return her money. Instead
of complying, he filed the petition. She reiterated her demand for a
refund. He gave her a copy of the court order to move to publish the
summons. The petition was dismissed as she refused to make an
affidavit as to her husband’s whereabouts. She filed an estafa
complaint which was referred to the IBP by the fiscal. He filed a
comment denying that he defrauded her. He insisted that he only
gave her a draft complaint and he had no idea who put the fake
stamp. He asserted that he did file the petition only that it was
dismissed due to her fault. SUSPENDED. He violated Rule 1.01 with
his deceitful conduct. He breached his Oath as he was not forthright
and honest in his dealings with her. He engaged in deceitful conduct
by presenting a bogus complaint allegedly with the court’s stamp.
Even after she ended their relations, he filed a second complaint to
cover up his earlier negligence and thwart her recovery of her
money. His repeated duplicity toward her reflected his lack of
integrity which clearly violated the oath he took before becoming a
lawyer. A court officer is expected to strictly adhere to the rigid
standards of mental fitness, maintain the highest degree of morality
and faithful compliance with the rules of the legal profession. Lina-ac
certainly lacked the essential requisite of probity and moral fiber for
his continued Bar membership.
Sps. Zialcita vs. Atty. Latras, AC#7169, 3/11/2019
Spouses Zialcita allegedly sign an P11-million pacto de retro sale

notarized by Latras as a collateral for a loan from Ester. They
claimed that Latras and Ester conspired to substitute the deed’s first
page with a P2-million deed of absolute sale. Latras denied the
imputed substitution. He argued that they had the burden to prove
the alleged fraud. NO PROOF OF ALLEGED CONSPIRACY.
Complainants failed to present evidence to substantiate their claim
of forgery and fraud on Latras’ part. It is elementary that clear and
preponderant evidence is the required quantum of proof in
administrative complaints for disbarment and suspension of lawyers.
Sps. Zialcita vs. Atty. Latras, AC#7169, 3/11/2019
Spouses Zialcita allegedly sign an P11-million pacto de retro sale

notarized by Latras as a collateral for a loan from Ester. They
claimed that Latras and Ester conspired to substitute the deed’s first
page with a P2-million deed of absolute sale. They added that he
notarized the deed without their knowledge and appearance. He
countered that one of them asked him to dispense with their
appearance. He insisted that the affirmation as to the contents and
truth stated in the document showed that the notarization
substantially complied with the requisites of the notarial law.
SUSPENDED, COMMISSION REVOKED WITH 2-YEAR PROHIBITION
AS A NOTARY. Sec. 1, Rule II and Sec. 2, Rule IV of the 2004 Notarial
Rules emphasize the necessity of the parties personally appearing
before the notary. Latras was liable for notarizing the subject
document without the spouses personally appearing before him. He
could not point to mere compliance with their instruction to notarize
the document without their present to avoid his responsibility. That
he talked to them on the phone and verified their signatures on the
document through the witnesses present were of no moment. The
parties must personally appear before the notary in the notarization
of the documents. The purpose of such appearance by the
acknowledging party before the notary is to enable the latter to
verify the genuineness of the former’s signature.
Basigsig vs. Atty. Aquino, AC#12362, 7/3/2019
Joey, an OFW in Korea, authorized Aquino to represent him in his

annulment case against his wife Robielyn. The latter accused Aquino
of overstepping his authority by filing Joey’s adultery complaint
against her. COMPLAINT DISMISSED. He apparently exceeded his
limited authority to file an annulment case since only the offended
spouse can prosecute the private offense that is adultery. However,
the adultery complaint filed only demonstrated his overzealousness
to advance his client’s cause. Said filing was not a malicious attempt
to misuse procedural rules. It was best to leave the effect of his
representation in that regard for the office where the criminal case
was filed to appreciate. The imputed act did not tend to lessen public
confidence in the profession’s fidelity, honesty and integrity in any
degree.
Sps. Regulto vs. Atty. Teoxon, AC#10301, 4/3/2019
Spouses Regulto were the respondents in a certiorari petition. The

CA issued an order waiving their right to comment on the petition
due to failure to file a comment. Commenting on the CA order, they
expressed their surprise since they had paid and expected Teoxon to
do his job. In fact, they frequented his office to remind him to file
their comment. Treating their comment as a disbarment case, the
Court ordered Teoxon to answer. He failed to comply. SUSPENDED.
He violated Rule 18.03 by failing to file the required comment. His
actions were a manifestation of his negligence. He was remiss in his
duty as counsel. He failed to comply with the utmost diligence
required of him as a lawyer and Bar member. A lawyer’s mere failure
to perform the obligations due to his client is per se a violation.
Counsel’s failure to submit the required brief within the reglementary
period is an offense that entails disciplinary action.
Justice Peralta vs. Atty. Ramon, AC#12415, 3/5/2019

Justices Peralta, Cruz and Hernando executed a joint complaint-
affidavit alleging that they checked their cases when Maria went to
CA to verify “their” decision acquitting her cousin Fajardo from a
drug charge. They confirmed that the case was with Justice Tijam
and still in the completion stage. Maria received the decision from
Ramon who supposedly told her to pay a huge sum to have the
decision promulgated. The justices also heard from the news that the
NBI had filed estafa and falsification charges against Ramon after
she was entrapped receiving mark money from Fajardo’s friend
Aquino. Ramon did not file her answer or attend CBD hearings
despite notices. DISBARRED. She violated the Oath and the Code.
She represented to Maria and Aquino that she could secure
Fajardo’s acquittal. She even named justices to accomplish her ill-
motives. She defrauded her clients by drafting a fake, spurious and
sham acquittal decision. She placed the justices’ names in the fake
decision even though the case was raffled to another division and
assigned to a different justice. She wrongfully involved the justices’
names in her fraudulent scheme and thus, disrespected and
discredited members of the Judiciary.
Tabao vs. Atty. Lacaba, AC#9269, 3/13/2019
Tabao accused Lacaba of notarizing the counter-affidvit to the

perjury case she and her siblings filed without the presence of two
respondents – Maria was in Dubai and Marie was in Cebu City. In
fact, their mothers signed the document which did not have any
document number, page number, book number and series year of
the notarial register. Lacaba explained that the investigating fiscal
knew, but did not object to the two affiants’ absence. He added that
he was on video-call with the absentees when he notarized the
document. Citing the Rules on Electronic Evidence, he argued that
the video-call substituted for personal appearance. COMMISSION
REVOKED, SUSPENDED WITH 2-YEAR PROBITION AS A NOTARY.
He did not dispute notarizing the counter-affidavit without all affiants
being personally present. A notary must not notarize a document
unless the signatories are the very same persons who executed and
personally appeared before him to attest to the contents and truth of
its statements. This is for the notary to verify the genuineness of the
acknowledging party’s signature and to ascertain that the document
is the party’s free act and deed. He also did not address his failure to
indicate his notarial register’s document, page and book number
and series years in the document. Such omissions violated Sec. 2(b)
and (e), Rule IV of the Notarial Rules.
Atty. Agustin vs. Atty. Laeno, AC#8124, 3/19/2019
Agustin’s sister represented their mother in buying a house and lot

from E.M. Laeno and Associates for P6.5-million. She rented out the
property to Laeno but later asked him to vacate for not paying rent.
After the filing of an ejectment case against Laeno, it was discovered
that Laeno executed two deeds for the property’s sale to Agustin’s
mother. Both deeds were undervalued at P2-million and P2.5-million
and had the same notarial entries. Laeno even offered one deed as
evidence in his disbarment case. SUSPENDED. His act of executing
two deeds of sale covering one single property with an undervalued
consideration to what the parties agreed on and offering one of the
bogus deeds as evidence before the Court is exactly what Canon 1,
7, 10 and 12 proscribes.
Fr. Zafra vs. Atty. Pagatpatan, AC#12457, 4/2/2019
Pagatpatan wrote the Bishop of Tandag to investigate Zafra’s

activities of concocting stories against his clients. He alleged that
Zafra committed a “mortal sin” by suing his clients for estafa.
Although cleared by the Board of Consultators and the Bishop, Zafra
filed a disbarment complaint as he was embarrassed by the
malicious letter. FINED. He committed simple misconduct since he
did not only espouse his client’s case when he wrote the letter. His
letter was not based on a sincere purpose of disciplining Zafra for
his actions but mainly to threaten and force Zafra to settle the estafa
case. He simply did not want the estafa case to proceed to full-blown
trial. That the letter was filed with the Bishop was inconsequential. A
Bar member is an oath-bound servant of the law. His first duty is to
the administration of justice and not to his client. His conduct must
be scrupulously observant of law and ethics. Here, malice motivated
the lawyer’s writing of said letter. Lawyers are duty-bound, in
keeping with the profession’s dignity, to abstain from all offensive
personality and advance no fact prejudicial to the honor or
reputation of a party or witness unless the justice of the cause he is
charged with requires it.
Fr. Zafra vs. Atty. Pagatpatan, AC#12457, 4/2/2019
Pagatpatan wrote the Bishop of Tandag to investigate Zafra’s

activities of concocting stories against his clients. He alleged that
Zafra committed a “mortal sin” by suing his clients for estafa. The
Board of Consultators and the Bishop cleared Zafra but the latter still
filed a disbarment complaint as he was embarrassed by the
malicious letter. He accused Pagatpatan of unauthorized law
practice because of a 2005 suspension order (in AC#4562). The SC-
PIO confirmed that said order had not yet been lifted. Pagatpatan
admitted that he engaged in law practice despite his suspension. He
said that he needed to maintain and sustain his family’s needs
especially with his wife’s ailment and eventual demise. DISBARRED.
There was no record of service of the suspension or a motion to lift it.
He made a mockery of the Court’s authority when he defied the
suspension order for over 11 years. He would have kept ignoring the
suspension order had Zafra not complained. His actions were gross
misconduct under Sec. 27, Rule 138RC – a sufficient ground to
suspend or disbar. Law practice, being a mere privilege and not a
right, must bow to the Court’s inherent regulatory power to exact
compliance with the lawyer’s public responsibilities. Pagatpatan’s
wanton disobedience of his duties as a court officer showed utter
disrespect for the Court and the legal profession.
Salazar vs. Atty. Quiambao, AC#12401, 3/12/2019
Diaz and Urisantos sold two lots to Salazar. Quimbao was hired to
notarize and process the sale and transfer. He was given the titles
and other relevant documents. Salazar paid P170,00 for his services.
Urisantos gave him P271,748.35 for tax payment. Eight months
passed with no update. Salazar tried to follow-up but he was always
out of reach. He failed to heed her letter reminding him of his duties.
He did not comply with her final demand to return the documents and
her money. He failed to answer, file his position and attend the CBD
hearing. SUSPENDED. Canon 16, Rule 16.01, 16.02 and 16.03
requires a lawyer to duly account for all moneys and properties of
his client. On the other hand, Canons 17, 18 and Rule 18.03 requires
that a lawyer exercise fidelity, competence and diligence when
dealing with his client. Quiambao received P170,000 from Salazar for
the processing, title transfer and other related fees including his
professional fee. Evidently, she gave him such amount to facilitate
the transfer of titles to her name. She and the sellers even gave him
the titles and other relevant documents. However, he failed to
comply with his obligation. Further, he could not explain where the
money went. Manifestly, he utterly failed to account and safe-keep
his client’s hard-earned money.
Chan vs. Atty. Cabrera, AC#10439, 9/3/2019
Ana, married but separated cohabited with a man whom she said
claimed to be a widower. She was pregnant with his child when she
learned that his wife was still alive and confined for “schizophrenia.”
She filed a disbarment complaint after he left her to return to his
family. She later expressed her disinterest to pursue the case. She
alleged that she was just induced by people with a grudge against
him and that the IBP lady staff made an exaggerated English
translation of her original Tagalog complaint. MOTION DENIED. Her
disinterest in the complaint did not necessarily free him from any
liability he may have already incurred. Her motion was not a bar to
investigate the administrative case against him. Sec. 5, Rule 39-B
states that no investigation shall be interrupted or terminated by
reason of desistance, settlement, compromise, restitution,
withdrawal of the charges or complainant’s failure to prosecute the
same. Bar members must conform to the highest moral standards
and the Court is bound to ensure compliance therewith. Any
deviation initially raised as complainant’s private concern becomes
a matter of judicial interest.
Chan vs. Atty. Cabrera, AC#10439, 9/3/2019
Ana, married but separated, cohabited with a man whom she said
claimed to be a widower. She was pregnant with his child when she
learned that his wife was still alive and confined for “schizophrenia.”
She filed a disbarment complaint after he left her to return to his
family. DISBARRED. A married person’s abandonment of his/her
spouse to live and cohabit with another constitutes immorality. The
offense may even be criminal – either as adultery or concubinage.
Immoral conduct or immorality is so willful, flagrant, shameless as to
show indifference to the opinion of good and respectable community
members. As a basis for disciplinary action, such must be so corrupt
as to virtually constitute a criminal act or so unprincipled as to be
reprehensible to a high degree or committed under such scandalous
or revolting circumstances as to shock the common sense of
decency.
Yap vs. Atty. Dantes, AC#11741, 6/19/2019
Dante filed an appeal notice for Yap and his co-plaintiff after their
civil case was dismissed. The CA dismissed the appeal due to
Dantes’ failure to file the appeal brief. Dantes cited sickness and
inclement weather as reasons for his remiss. REPRIMANDED. He
was 85 years old and this was his first offense. He was guilty of
inexcusable negligence in violation of Canon 18. His failure to timely
file the brief leading to dismissal constituted negligence. He also
violated Rule 18.04 since he did not tell his clients the case status,
other than his letter apprising them of the dismissal and ending their
attorney-client relationship.
Anima vs. Prosecutor Penaco-Rojas, AC#10121, 4/1/2019
Anima complained that Fiscal Rojas deliberately did not resolve the
estafa and theft cases he filed. He added that she made sure that he
did not receive a copy of her resolution. She countered that she
issued the resolution dismissing his cases due to insufficient
evidence three months from submission. She explained that the
resolution was forthwith sent to the docket section for mailing.
COMPLAINT DISMISSED. Anima’s charges against her involved her
functions as a prosecutor. The filing of the complaint should have
been with the Ombudsman. The act complained of was within the
Ombudsman’s disciplinary power since her alleged failure to furnish
him a copy of the resolution was an exercise of official function as
contemplated under the law. A line exists between accountability of
government lawyers as public officers and as Bar members. The IBP
has no jurisdiction to investigate government lawyers charged with
administrative offenses in the exercise of their official duties and
function. The Justice Secretary has disciplinary authority over
government lawyers. Under Sec. 15(1), RA6770, the Ombudsman
also has disciplinary jurisdiction over government lawyers as public
officials.
Muntuerto vs. Atty. Alberto, AC#12289, 4/2/2019
Alberto, as Dinopol’s counsel, filed a recovery complaint against

Singhil Hydro Builders. He made Dinopol sign and file a “Motion for
Prior Leave of Court to Admit Amended Complaint” with attached
amended complaint after he realized his fatal defect, i.e. he did not
indicate his MCLE Compliance in the complaint. SUSPENDED. He
flagrantly disobeyed the resolution issued in BM#1922 when he failed
to disclose his MCLE Compliance and its date of issue. The rule
required him to disclose his MCLE Compliance in all pleadings,
motions and other papers filed in court. The Court en banc resolution
(1/14/2014) amended BM#1922. It repealed the phrase “failure to
disclose the required information would cause dismissal of the case
and the expunction of the pleadings from the records” and replaced
it with “failure to disclose the required information would subject the
counsel to appropriate penalty and disciplinary action. For non-
disclosure of current MCLE compliance/exemption number in the
pleadings – fine of 2,000 for first offense; P3,000 for second offense
and P4,000 for third offense and counsel may be listed as a
delinquent Bar member pursuant to Sec. 2, Rule 13 of BM#850. A
non-compliance lawyer shall be discharged from the case and the
client shall be allowed to engage new counsel with the concomitant
right to demand the return of fees already paid to the non-compliant.
Muntuerto vs. Atty. Alberto, AC#12289, 4/2/2019
Alberto, as Dinopol’s counsel, filed a recovery complaint against

Singfil Hydro Builders. He attached supplemental and joint venture
agreements to the complaint. He ante-dated his notarization of both
agreements. The notarial division certified that there was no record
of said documents or his commission. He later failed to comply with
the IBP order to comment. PERMANENT BAN AS A NOTARY. He
vested the document with evidentiary value by making it appear that
he was a duly commissioned notary. He was guilty of dishonesty as
he foisted a deliberate falsehood on the trial court due to absence of
a commission. He trivialized the solemnity of notarizing documents.
Such effrontery transgressed the prohibition against unlawful,
dishonest, immoral or deceitful conduct on his part as a lawyer made
explicit in Rule 1.01, Canon 1.
Achacoso vs. Judge Garces, AM#MTJ-19-1923, 9/4/2019
Marapao was Nimfa’s counsel in criminal cases against Lorgina. He

manifested that he could no longer prosecute the cases after Nimfa
was assassinated. Acting on accused’s motion, Garces ordered the
cases dismissed. Nimfa’s brother Achacoso complained that the
dismissal order was improper since the fiscal and interested parties
were not given a chance to air their side. COMPLAINT DISMISSED.
There was no showing that prosecution questioned the dismissal
order either through a motion for reconsideration or appeal before
the higher court. A judge’s error in the exercise of judicial functions
cannot be corrected thru administrative proceedings. Administrative
complaints against judges and justices are not substitute for appeal
and other judicial remedies against an assailed decision or ruling.
Assuming that Garces erred in his order, a judge cannot be civilly,
criminally or administratively liable for such judicial error, no matter
how erroneous, as long as he acted in good faith. Otherwise, judicial
office would be untenable for no one called upon to try facts and
interpret laws in the process of administering justice can be infallible
in his judgment.
Achacoso vs. Judge Garces, AM#MTJ-19-1923, 9/4/2019
Marapao was Nimfa’s counsel in criminal cases against Lorgina. He

moved for Garces to inhibit from the cases. Garces ordered defense
counsel to comment on the motion within 10 days. The motion was
still pending when Marapao manifested that he could no longer
prosecute the cases due to Nimfa’s demise. Garces granted
accused motion and dismissed the cases for lack of interest. Nimfa’s
brother Achacoso complained that Garces failed to act on the
inhibition motion. Garces insisted that the motion was moot and
academic since Marapao withdrew. FINED P10,000. His failure to
resolve the inhibition motion merited administrative sanction.
Without having applied for an extension before the Court, he was
bound to resolve the pending motion within the 3-month period
prescribed by the Constitution. Instead, he ascribed his failure to
resolve the motion to Marapao’s withdrawal. For him, this rendered
the issue moot and academic. SC Admin Cir. No. 13-87 provides that
judges shall observe scrupulously the periods prescribed by Sec. 15,
Art. VIII, 1987 Constitution for adjudication and resolution of all
cases or matters submitted in their courts. It was incumbent upon
him to resolve the same within the prescribed deadline. In this
respect, his failure to perform his judicial duty with reasonable
promptness also violated Sec. 5, Canon 6. To accept his excuse
would be giving imprimatur to the act of deferring resolution on a
pending incident until an event supervenes and renders the issue
moot. Taking delays lightly would be an abject abandonment of a
magistrate’s sworn duty.
Judge Macapagal vs. Atty. Young, AC#9298, 7/29/2019
Macapagal complained to the OBC that Young wrote her a letter with
threats of administrative and criminal cases if the writ she issued in
an expropriation case was enforced. Young explained that his main
purpose in writing was to avert eviction of the informal settlers. He
denied intent to malign and to threaten her – he even labeled the
envelope as “confidential.” He deemed his letter as an act of
courtesy, “a cautionary notice” to warn and stop her from a judicial
transgression upon his client’s basic right to due process.
REPRIMANDED. It was highly improper and violative of Canon 11 for
him to send the letter. His letter did make the imputed threats. His
statements showed that he failed to observe respect due to the
courts and to judicial officers. Both as court officers and as citizens,
lawyers have a right to criticize the acts of courts and judges in
properly respectful terms and through legitimate channels. Such
criticisms, no matter how truthful, shall not spill over the walls of
decency and propriety.
Judge Macapagal vs. Atty. Young, AC#9298, 7/29/2019

Macapagal complained to the OBC that Young wrote her a letter with
threats of administrative and criminal cases if the writ she issued in
an expropriation case was enforced. Young explained that his main
purpose in writing was to avert eviction of the informal settlers. He
denied intent to malign and to threaten her – he even labeled the
envelope as “confidential.” He deemed his letter as an act of
courtesy, “a cautionary notice” to warn and stop her from a judicial
transgression upon his client’s basic right to due process.
REPRIMANDED. While he violated Canon 11, it was proper to lower
the penalty since this was his first offense and he was of advanced
age. The Court in determining the penalty to impose considers the
facts and factors which may serve as mitigating like respondent’s
acknowledgment of his/her infraction and remorse, family
circumstances, respondent’s advanced age, humanitarian and
equitable considerations, among others.
Sps. Vargas vs. Atty. Orino, AC#8907, 6/32019
Orino defended Nestor and co-defendants in a forcible entry case.

He failed to attend hearings and to submit the position paper. He
even failed to submit the appeal memorandum which prompted the
CA to dismiss their appeal. His reply to Nestor as to why he did not
file the position paper was – “hindi ko na sinagot dahil talo na kayo sa
forcible entry. Sa lupa na lang kayo maghabol.” He averred that he
only took the case because some defendants supported his bind as
Board member and mayor. His plan was to withdraw after he
reviewed and found their case to be frivolous but he was busy with
the 2010 elections. SUSPENDED. He violated a basic postulate in
legal ethics – Rule 18.03, Canon 18. A lawyer-client relationship was
created when he accepted their case and received payment from
them. He failed to serve his clients with industry and diligence,
neglected the legal matter entrusted to him and attributed his
shortcomings as a lawyer to being a politician. Such reason was
unacceptable, if not a display of insolence and arrogance.
Alipio vs. Atty. Era, AC#12470, 4/1/2019
A disbarment complaint was filed against Era for violation of BP#22.

COMPLAINT DISMISSED. The subject checks were dishonored upon
presentment. However, the sales transaction for which Era issued
them as part of the purchase price did not push through due to the
belated discovery of a notice of lis pendens affecting the property
sold. Ergo, said checks were not issued to apply for account or for
value. Their dishonor was not in violation of BP#22 or a ground for
disciplinary action against Era.
Domingo vs. Atty. Sacdalan, AC#12475, 3/26/2019
Domingo paid Sacdalan his acceptance fee with a P50,000 deposit

for expenses to recover a lot she and her sister owned. He asked for
a P200,000 advance for his wife’s hospitalization. She took pity and
lent him P100,000 deductible from his appearance and other fees.
He gave her a copy of the court-stamped “received” complaint. She
learned that she had a fake copy when the MTC told her no case was
filed. He blamed his staff for the fake copy and promised to file the
complaint. The MTC dismissed the complaint he filed due to lack of
jurisdiction. Dissatisfied with his work, she ended his services and
demanded the return of her P150,000. DISBARRED. Rule 1.01
requires lawyers to maintain a high standard of legal proficiency,
morality, honesty, integrity and fair dealing. His flimsy excuse of
blaming his staff was unacceptable. The first page of the complaint
showed that it was not properly filed – the words “MTC” and date
were only handwritten on the received stamp. The complaint’s
document number was merely handwritten. These were not standard
operating procedures in filing a complaint. As a lawyer, he should
have noticed these irregularities before he gave his client a copy.
Also, he gave no concrete details as to the consequences his staff
incurred, i.e. whether criminal or disciplinary charges were filed for
faking the received copy. Still, he could not “pass the buck” to his
staff and escape liability. His sworn duty was to observe due
diligence and honesty in dealing with his client. He deceived his
client by delivering a fake copy. Thus, he participated in deceitful
conduct toward his client in violation of Rule 1.01.
Domingo vs. Atty. Sacdalan, AC#12475, 3/26/2019
Domingo paid Sacdalan his acceptance fee with a P50,000 deposit

for expenses to recover a lot she and her sister owned. He asked for
a P200,000 advance for his wife’s hospitalization. She took pity and
lent him P100,000 deductible from his appearance and other fees.
He gave her a copy of the court-stamped “received” complaint. She
learned that she had a fake copy when the MTC told her no case was
filed. He blamed his staff for the fake copy and promised to file the
complaint. The MTC dismissed the complaint he filed due to lack of
jurisdiction. Dissatisfied with his work, she ended his services and
demanded the return of her P150,000. DISBARRED. Rule 16.04
prohibits a lawyer from borrowing money from a client to prevent
him from taking advantage of his influence over the client. He had no
basis for the cash advance when his legal services were terminated.
Aside from his bare claim that the nature of the case or independent
advice fully protected the money loaned, he provided no justification
or detail about such protection. Asking a client for a loan, like what
he did, was very unethical and an abuse of the client’s confidence.
The canon presumes the client to be at a disadvantage due to the
lawyer’s ability to use legal maneuverings to renege on his
obligation. A lawyer must not borrow from his client unless the
latter’s interests are fully protected.
Atty. Bartolome vs. Atty. Basilio, AC#10783, 1/31/2018
A decision suspended Basilio for 1 year with a 2-year ban as a notary

for violating the Notarial Rules and Canon 1. He got a copy of the
decision 2 months after its issuance. His motion for reconsideration
was denied 5 months from when the issuance of the decision.
Meanwhile, Rambayon wrote two letters reporting to the Court that
Basilio still appeared before a municipal court and that his name
appeared in 5 cases listed in the RTC case schedule. Both letters
prompted the OCA to issue show-cause orders. Basilio complied and
explained that he did not forthwith comply with the suspension order
due to his belief that his motion for reconsideration suspended the
order. He honestly thought that what was immediately executory was
the revocation of his commission. FINED P10,000. He received the
decision but failed to immediately serve the penalties. His belief that
only his commission’s revocation and prohibition as notary were
executory was an unacceptable flimsy excuse. The wording of the
decision was unequivocal and the clause “effective immediately”
was placed at the end of the enumerated penalties, thus, indicating
that the same pertained to and qualified all three penalties including
suspension.
Lim vs. Atty. Rivera, AC#12156, 6/20/2018
The check Rivera issued to cover his loan with Lim bounced. Lim
filed a disbarment complaint. Rivera did not answer or attend the
hearings despite notice. SUSPENDED. His failure to answer and
attend the hearings despite notice was evidence of his flouting
resistance to lawful orders and illustrated his despiciency for his
Oath in violation of Sec. 3, Rule 138RC. He should have stood
foremost in complying with IBP-CBD directives because, as a lawyer,
he was called upon to obey legal orders of duly constituted
authorities and also because the case involved the very foundation
of his right to practice law.
Judge Dumlao vs. Atty. Camacho, AC#10498, 9/4/2018
Camacho was plaintiff’s counsel in a civil case assigned to Dumlao.

He tried to fraternize with the judge even name-dropped important
persons like CJ Sereno and Justice Leonen. He called Dumlao,
promised a portion of his fees if defendant’s appeal notice was
denied and an execution writ issued and threatened to disbar the
judge if the offer was rejected. He saw Dumlao to expedite execution
and threatened to sue the judge and sheriff if a garnishment order
was not signed despite available personal properties to satisfy
execution. He later sent the judge text messages threatening to file
cases. Given his previous disbarment, SUSPENDED. Canon 19
enjoins a lawyer to represent his client with zeal within the bounds of
law. A lawyer’s duty is not to his client but to the administration of
justice. Client’s success is wholly subordinate. A lawyer’s conduct
must always be scrupulously observant of law and ethics. Under
Rule 19.01, a lawyer should not file or threaten to file a baseless or
unfounded criminal case against his client’s adversaries designed to
secure leverage to compel the adversaries to yield or withdraw their
own cases against his client.

denied and an execution writ issued and threatened to disbar the
judge if the offer was rejected. He saw Dumlao to expedite execution
and threatened to sue the judge and sheriff if a garnishment order
was not signed despite available personal properties to satisfy
execution. He later sent the judge text messages threatening to file
cases. Given his previous disbarment, SUSPENDED. His influence-
peddling, bribery attempt, threats against court officers and
disrespect of court processes were violations of the Code and the
Oath. Lawyers should always live up to the profession’s ethical
standards as embodied in the Code. A Bar member’s improper and
irresponsible conduct may erode public confidence in law and
lawyers. Every lawyer should act and comport himself in a manner
promoting public confidence in the profession’s integrity. Without
invading any constitutional privilege or right, an attorney’s right to
practice law may be resolved by a proceeding to suspend or disbar
him, based on conduct rendering him unfit to hold a license or to
exercise an attorney’s duties and responsibilities.
Sioson vs. Atty. Apoya, AC#12044, 7/23/2018
Sioson filed a qualified theft complaint. The fiscal dismissed the

complaint. Sioson paid Apoya P10,000 to petition for review. He
asked for an update. Apoya replied that he would enter his
appearance. Later, Apoya said that he was waiting on the DOJ order
on his entry. Sioson learned from the DOJ that no entry was made.
He called Apoya but the latter could not be reached. He wrote to ask
for an update. This letter was received by “Juvy.” His second letter
for a refund was received by Apoya’s mother. In answer to Sioson’s
disbarment complaint, Apoya denied knowing Sioson, receiving
money or being engaged. He argued that he even sued Sioson for
grave threats and coercion afer receiving the letters. SUSPENDED.
Canon 1 mandates a lawyer to obey the laws and legal processes. He
is expected to respect and abide by the law to the best of his ability.
He must avoid any act or omission that is contrary to the law. His
personal deference to the law speaks of his character and inspires
the public to also respect and obey the law. Rule 1.01 states the
norm of conduct all lawyers must observe. Any act or omission
contrary to, prohibited or unauthorized by, or in defiance of,
disobedient to or disregards the law is unlawful. A Bar member
should not do anything tending to lessen public confidence in the
profession’s fidelity, honesty and integrity.
Yap vs. Atty. Buri, AC#1116, 3/19/018
Yap sold her condo unit to Buri. She allowed occupancy after Buri
promised full payment of the P200,000 balance. Buri later offered to
pay the balance on installment. Yap refused. Buri threatened to
rescind the sale, demanded a refund then sued Yap for estafa. NO
AWARD AS TO THE P200,000 BALANCE. Said amount was not
intrinsically linked to Buri’s professional engagement. Disciplinary
cases revolve around determining respondent’s administrative and
not civil liability. Purely civil liabilities, like those involving money the
lawyer owes his client in a separate and distinct transaction and not
due to lawyer-client relations, should be threshed out in a separate
civil action.
Gonzales vs. Atty. Santos, AC#10178, 6/19/2018
Gonzales hired Santos to secure her title. He failed to deliver.

Instead, his niece used a forged power of attorney to mortgage the
property. SUSPENDED. He was expected to deliver said title upon
demand. His failure to timely turn it over led to, if not, facilitated his
niece’s fraudulent mortgage only days after the title issued. The
highly fiduciary attorney-client relationship exacts a great fidelity
and good faith from a lawyer. He is required by Rule 16.01 to account
for money and property received or collected for or from clients.
Rule 16.03 also commands him to deliver the client’s funds or
property when due or upon demand.
Palencia vs. Atty. Linsangan, AC#10557, 7/10/2018
Respondents and their paralegal frequently visited Palencia who was

rehabbing in the hospital from a work-related injury from a fall down
an elevator shaft of a Cyprus vessel. They convinced him to hire
them and a Singaporean firm to sue his employer. From a P20,000
award, Respondent charged 35% attorney’s fees. A later $90,000
award was given by the Singaporean High Court from which the
Singaporean firm deducted $59,000. After Respondents deducted
their fees and expenses, $18,000 was left for Palencia. He contested
the deductions and refused to settle for $20,000. SUSPENDED.
Respondents Pedro and Gerard violated Rule 2.03 and Canon 3.
They committed malpractice when they indirectly solicited legal
business and employed paralegals to convince Palencia to sue.
Lawyers must make their legal services known in a dignified manner.
They are prohibited from soliciting cases for gain personally or
through paid agents. A lawyer’s “ambulance chasing” or solicitation
of any business either personally or through an agent is proscribed.
Go vs. Atty. Buri, AC#12296, 12/4/2018
Go paid Buri P150,000 to annul her marriage. She told Buri to hold
the petition while she dealt with personal problems. Buri withdrew
the petition. Two years later, Go paid Buri P38,000 to proceed/re-file
the petition. She grew suspicious when Buri failed to give copies of
the original and re-filed petitions. She was told by the Clerk of Court
that no petition was filed. She had lost trust and demanded a refund.
Buri promised but failed to return the money. SUSPENDED. She
violated Rule 16.01 and 16.03 when she failed to return the P188,000
despite demands. The highly fiduciary attorney-client relationship
prescribes a great fidelity and good faith from the lawyer. This
imposes a duty for him to account for money or property received or
collected for or from the client. A lawyer’s failure to return such
funds upon demand raises the presumption that he appropriated the
same for his own use in violation of the trust reposed in him. This act
is a gross violation of general morality and professional ethics.
Go vs. Atty. Buri, AC#12296, 12/4/2018
Go paid Buri P150,000 to annul her marriage. She told Buri to hold
the petition while she dealt with personal problems. Buri withdrew
the petition. Two years later, Go paid Buri P38,000 to proceed/re-file
the petition. She grew suspicious when Buri failed to give copies of
the original and re-filed petitions. She was told by the Clerk of Court
that no petition was filed. She had lost trust and demanded a refund.
Buri promised but failed to return the money. SUSPENDED. She
violated Rule 1.01 when she misrepresented that she filed the first
petition, later withdrew it and filed a second petition when no petition
was filed. As court officers, lawyers are bound to maintain a high
standard of legal proficiency, morality, honesty, integrity and fair
dealing. Buri fell short of such standard with her deception and
misrepresentation. Her acts were disgraceful, dishonorable and
unacceptable to the profession. They showed basic flaws making her
unfit to practice.
Flora III vs. Atty. Luna, AC#11486, 10/17/2018
Flora paid Luna P43,500 for acceptance and appearance fees for his
intended criminal cases against an Indian national. He asked for a
refund as the issued was resolved at the barangay and the cases
were never filed. Luna refused and even shouted that the money was
not enough for his services. ORDERED TO RETURN THE MONEY
WITH 6% INTEREST. He had no reason to keep the money or even
ask for it in the first place. He unjustifiably refused to return the
money. He had had no right to retain it since he did not render any
legal service. Lawyers are not required to assist the parties in
barangay mediation proceedings. Acceptance fee is generally non-
refundable but it presupposes that the lawyer rendered legal service
to the client. Return of acceptance fee is allowed when a lawyer
completely fails to render legal service.
Atty. Roque vs. Atty. Balbin, AC#7088, 12/42018
Balbin started to harass and intimidate Roque after his clients lost a
civil case to Roque’s clients. He wanted Roque to withdraw the case
so he called and sent texts and e-mails to Roque and the latter’s
family threatening to file and publish criminal and disbarment cases
to besmirch and/or destroy Roque’s name, reputation and high
profile stature. SUSPENDED. His threats of baseless administrative
and criminal cases to strong-arm Roque and his client to submit
contravened the Oath’s mandate for lawyers not to wittingly or
willingly promote or sue any groundless, false or unlawful suit, nor
give aid or consent to the same. It violated Rule 19.01, Canon 19.
profile stature. SUSPENDED. He aggravated his liability by asking for
an extension without filing the comment which resulted in fines and
an arrest order. Such audacity violated Canons 11 and 12 as it
caused undue delay in resolving the case. He disrespected the
judicial institution as court orders are not mere request to be
partially, inadequately or selectively complied with. Obstinate
refusal or failure to comply betrays a recalcitrant flaw in a lawyer’s
character which underscores disrespect to the Court’ lawful orders
that deserves reproof. Bar members owe courts respect, courtesy,
and such other becoming conduct essential to promote orderly,
impartial and speedy justice.
profile stature. SUSPENDED. His underhanded tactics violated
Canon 8. He resorted to personal attacks against opposing counsel
instead of using remedies to contest the adverse ruling. His repeated
intimidation, harassment and blackmail were tools to return the
inconvenience his clients suffered. His actions were a misuse of the
legal processes available to him and his client. Every lawsuit’s aim
should be to render justice to the parties according to law and not to
harass them. He showed a lack of respect and despicable behavior
towards a colleague and conduct unbecoming of a Bar member.

denied and an execution writ issued with a threat to disbar Dumlao if
the offer was rejected. He saw Dumlao to expedite execution and
threatened to sue the judge and sheriff if a garnishment order was
not signed despite available personal properties to satisfy execution.
He later sent the judge text messages threatening to file cases.
Given his previous disbarment, SUSPENDED. A lawyer must not
disrespect court officers. Disrespect to judicial incumbents is
disrespect to the branch of the government to which they belong and
to the State which has instituted the judicial system. A lawyer’s duty
is to observe and maintain respect due to courts and judicial
officers. A lawyer who disrespects the court and its officers violates
Canon 11 and Rule 11.01CPR. Camacho’s acts were palpably
irregular and disrespectful to the court and its officers. He had the
gall to barge into the judge’s chambers and threaten the court
personnel. His wanted disregard of the good conducted expected
from lawyers before the courts violated Rule 11.03. He also violated
the Oath – to obey the laws as well as the legal orders of the duly
constituted authorities therein; to do no falsehood, nor consent to
the doing of any in court; and to conduct himself as a lawyer
according to the best of his knowledge and discretion, with all good
fidelity as well to the courts as to his clients.
Gov. Tallado vs. Hon. Racoma, AM#RTJ-18-236, 10/10/2018
The Sanggunian issued a resolution preventively suspending Mayor

Ang. Talledo issued the suspension notice. Ang filed a certiorari
petition. Racoma heard the petition and later issued a restraining
order (TRO) citing irreparable damage to Ang if the suspension was
enforced. Tallado accused Racoma of misconduct for baselessly
issuing the order. Racoma asked for time to comment but failed to do
so. COMPLAINT DISMISSED. No evidence showed that fraud, bad
faith or corruption motivated Racoma’s grant of the TRO. He
followed standard procedure in hearing the injunction case and aptly
explained his legal basis for issuing the TRO. That he misapplied the
jurisprudence he cited in the order will not make him liable. Not
every error or mistake by a judge in performing his official duties will
render him administratively liable. A judge’s official act is not subject
to disciplinary action absent fraud, dishonesty or corruption or
malice or ill-will, bad faith or deliberate intent to do an injustice. An
administrative case is not the proper remedy for a judge’s act
deemed aberrant or irregular. Such a case cannot be used as a
remedy to challenge the judge’s assailed order or decision nor can it
be used to substitute for other judicial remedies. A judge’s errors in
his adjudicative functions should be assailed through judicial
remedies and not corrected through administrative proceedings.
Gov. Tallado vs. Hon. Racoma, AM#RTJ-18-236, 10/10/2018
The Sanggunian issued a resolution preventively suspending Mayor

Ang. Talledo issued the suspension notice. Ang filed a certiorari
petition. Racoma heard the petition and later issued a restraining
order (TRO) citing irreparable damage to Ang if the suspension was
enforced. Tallado accused Racoma of misconduct for baselessly
issuing the order. Racoma asked for time to comment but failed to do
so. FINED P11,000. He failed to comply with the Court’s orders by
failing to submit the required comment. This revealed a failure to live
up to the standards required of a government employee. Under Sec.
9, Rule 140RC, violation of the Court’s rules, directives or circulars is
a less serious office. The fine imposed is proper since he had been
previously fined for undue delay in rendering judgment in AM#RTJ-
14-2373 and AM#RTJ-10-2233.
Carpio vs. Judge Dimaguila, AM#MTJ-17-1897, 11/21/2018
An order imposed a P10,000 fine on Dimaguila for failing to refer to

mediation the civil aspect of the grace coercion case against Sps.
Carpio. Dimaguila moved for reconsideration. MOTION PARTIALLY
GRANTED. Her failure to refer to mandatory Civil Aspect Mediation
(CAM) and JDR was not gross ignorance of the law. She may have
deviated from the procedure under AM#11-1-6-SC-PHILJA, but, it
was not outrageous so as to constitute gross ignorance. She was
only liable for the less serious charge of violating SC rules, directives
and circulars and not the serious charge of gross ignorance under
Sec. 8, Rule 40. Gross ignorance requires that issuance of the
assailed order or the judge’s actuation in performing official duties is
both erroneous and actuated by bad faith, hatred, dishonesty or
some other like motive.
Lopez vs. Atty. Cristobal, AC#12146, 10/10/2018
Lopez demanded that Cristobal withdraw her appearance and return

his P35,000 because she did not attend hearings, failed to file his
position paper and refused to communicate with him. She claimed
that her failure to file the position paper was because of his refusal to
pay her fees. SUSPENDED. Her defense for failing to file the position
paper had no merit. By such failure, she did not live up to her duties
as a lawyer under the strictures of the Oath and Code. She violated
Canon 18, i.e., a lawyer is duty-bound to competently and diligently
serve his client once the former takes up the latter’s cause. A lawyer
owes fidelity to such cause. He must always be mindful of the trust
and confidence reposed in him. His neglect of a legal matter
entrusted to him amounts to inexcusable negligence for which he
must be liable administratively.

position paper and refused to communicate with him. She averred
that she already returned his papers and P10,000. SUSPENDED. She
claimed that she was effectively discharged when she returned the
case record and he accepted the P10,000. Her defense of discharge
was self-serving. She violated Rule 22.01, Canon 22. An attorney can
retire from a case only either by client’s written consent or by court
permission after due notice and hearing in which event, he must see
to it that the new lawyer’s name is recorded in the case. A lawyer
who desires to retire from an action without his client’s written
consent must file a petition for withdrawal in court serving copies of
his petition on the client and adverse party at least 3 days prior to
the hearing date set. Otherwise, the court may treat the petition as a
“mere scrap of paper.” She never sought her client’s written consent
or court permission nor did she file a petition to withraw in court.

position paper and refused to communicate with him. She averred
that she already returned P10,000. ORDERED TO RETURN P25,000.
Return of said amount was proper. Her receipt of P35,000 was
undisputed. Disciplinary proceedings should only revolve around
determining respondent’s administrative and not his civil liability,
but, to clarify, this rule remains applicable only to claimed liabilities
which are purely civil in nature as when the claim involves moneys
received by the lawyer from his client in a transaction separate and
distinct and not intrinsically linked to his professional engagement,
such as acceptance fee.
Santos vs. Atty. Arrojado, AC#8502, 6/27/2018
Arrojado was Lilia’s counsel in an ejectment case against Santos.

Lilia eventually won the case but Santos accused Arrojado of
violating Art. 1491CC. She alleged that his son purchased a part of
the litigated lot while the appeal was pending with Arrojado himself
being a witness to the sale. COMPLAINT DISMISSED. He did not
violate Art. 1491CC. The son and not the lawyer was the buyer. To
include the lawyer’s immediate family or relatives within the law’s
purview would be amending the law. The law’s enumeration cannot
be stretched or extended to make such inclusion. Also, the article
prohibits acquisition made either in person or through an
intermediary. No evidence showed that Julius acted or mediated in
behalf of Arrojado or that the latter was the sale’s ultimately
beneficiary. His participation in the sale might have ruffled very
sensitive scruples but it was not prohibited per se.
Lehnert vs. Atty. Dino, AC#12174, 8/28/2018
Lehnert filed two counts of violation of BP#22 against Dino. A

warrant for Dino’s arrest was issued but despite exhaustive efforts,
the warrant was unserved. Lehnert prayed for immediate disbarment
since Dino was hiding to evade arrest. Dino did not appear or file any
brief to the CBD. SUSPENDED FOR 2 YEARS. The Court adopted the
findings that although he had not yet been convicted of the crime
charged, his act of evading arrest and faiing to participate in the
CBD administrative proceedings further gave the impression that he
was probably guilty. This court continues to state that the issuance
of worthless checks constitutes gross misconduct and violates
Canon 1 which mandates all Bar members to obey the laws of the
land and promote respect for law. Issuance of worthless checks also
violates Rule 1.01 which mandates that a lawyer shall not engage in
unlawful, dishonest, immoral or deceitful conduct.
Gradiola vs. Atty. Deles, AC#10267, 6/18/2018
Gradiola filed a disbarment complaint against Deles for allegedly

delegating his case to a disbarred lawyer and simulated a position
paper and a CA resolution supposedly favoring him even when the
case was already lost. Deles’ son reported to the IBP that Deles
suffered a stroke, underwent brain surgery and was in a vegetative
state. CASE REMANDED TO IBP. The disbarred lawyer might have
admitted to defrauding clients including Gradiola but, no conclusion
could yet be made as to Deles’ part in the racket. He could not air his
side given his medical condition. His son had to hire the lawyer to
prepare the answer and sign said answer. The serious imputations
required the observance of due process. Deles should be allowed to
explain his side but, due to his condition, he was not yet in a position
to factually dispute the charges.
Prosecutor Cahanap vs. Judge Quinones, AM#RTJ-16-2470,

1/10/2018
Cahanap charged Quinones of habitual tardiness resulting in delay in

the start of court sessions. This allegedly earned her the monicker of
“Branch 10” for usually starting at 10 a.m. She admitted to arriving
late but denied that it was habitual. She argued that her 60% disposal
rate refuted the punctuality issue. FINED P20,000. Judges are
reminded to faithfully observe the prescribed official hours to inspire
public respect for the judicial system. Daily sessions are from Mon-
Fri from 830 am to 12 noon and 2 to 4pm under Supervisory Circular
No. 14 (10/22/1985). Trial judges are enjoined by Circular No. 13
(7/1/1987) to strictly observe the daily minimum of 8 hours of service
with 5 hours for trial from 830 am to 12 noon and 2-430 pm. Session
hours of trial courts are set by Administrative Circular No. 3-99
(1/15/1999) from 830 am to 12 noon and 2-430 pm. All three circulars
restate the Canons which enjoins judges to be punctual in
performing their judicial duties recognizing that the time of litigants,
witnesses and attorneys is of value. A judge sets a bad example to
the bar and creates dissatisfaction in the administration of justice if
he is not punctual in his habits.
Domingo vs. Atty. Revilla, AC#5473, 1/23/2018
Domingo engaged Revilla’s firm to settle his mother’s estate and

rescind her adoption of his cousin Melchor. He paid P200,000 for the
judge in the rescission case, P50,000 for the “CA and SC boys” and
later P433,000 to influence the outcome of Melchor’s appeal from the
rescission case. He asked for copies of the decision. Revilla just
gave excuse and cut off communication. Domingo wrote the firm to
report Revilla but was informed that he was a client and Revilla had
been forced to resign due to client complaints. FINED as he had been
previously disbarred (AC#7054, 12/4/2009). His various offenses
were professional misconduct demonstrating his unworthiness to
remain a Bar member. Disbarment could not be imposed as this
jurisdiction does not have double disbarment. A heavy fine may be
imposed on a disbarred lawyer for an offense that is a ground prior
to his eventual disbarment. The Court’s jurisdiction is not lost over
his disbarrable acts committed while still a Bar member. The stiff
fine meted is the Court’s assertion of its authority and competence to
discipline all acts done by by a Bar member despite his disbarment.
Revilla’s voluntary restitution of the amount he received from his
professional engagement may not lift the sanction meted, still, it
manifested a degree of remorse for his wrongdoing that mitigated in
his favor.
Goopio vs. Atty. Maglalang, AC#10555, 7/31/2018
Cecilia was Maglalang’s former client. She introduced him to her

sister Goopio. To settle her realty contract dispute with a developer,
Goopio executed a power of attorney for Maglalang. She later
realized that she had been scammed into paying P484,000 for a
rescission case that was never filed. Cecilia had authored the shame
engagement by furtively using Maglalang’s computerized letterhead
and billing statements. REPRIMANDED. He committed material
negligence by his own admission that he failed to discover Cecilia’s
manipulations before matters worsened. A lawyer must exercise
care and diligence in conducting the affairs of his practice including
the observance of reasonable due vigilance to ensure that, to the
best of his knowledge, his documents and other implements are not
used to further duplicitous and fraudulent activities.
De Leon vs. Atty. Geronimo, AC#10441, 2/14/2018
De Leon hired Geronimo to ask for reconsideration from the NLRC

order increasing her liability to P1-million from the P5,000 awarded
by the Arbiter. She confronted him after learning that her motion had
been denied. He told her that appeal to the CA was immaterial since,
“wala ka naman pera!” SUSPENDED. Clients expect lawyers to be
ever-mindful of their cause and to exercise the degree of diligence
required in handling their affairs. Lawyers are expected to always
maintain a high standard of legal proficiency and to devote their full
attention, skill and competence to the case whether for a fee or for
free and regardless of its importance.
United Coconut Planters Bank vs. Atty. Noel, AC#3951, 6/19/2018
Noel failed to comment on an application for preliminary injunction

and to file answer. UCPB was defaulted, judgment was issued and an
execution writ issued. He assured UCPB that he would take care of
it. UCPB was forced to open an account to satisfy judgment when the
sheriff came to enforce the writ. SUSPENDED. His acts constituted
inexcusable negligence which warranted the Court’s exercise of its
power to discipline him. He grossly neglected his duty as counsel to
his client’s extreme detriment. He willingly and knowingly allowed
the default order to attain finality. He allowed judgment to be made
against his client based on ex parte evidence. He also knowingly and
willingly allowed said judgment to become final. He failed to assert
any remedy or defense available to his client under applicable laws.
Under Canon 17, lawyers owe fidelity to the client’s cause. They
must be mindful of the trust and confidence reposed in them.
Yoshimura vs. Atty. Panagsagan, AC#10962, 9/11/2018
For their application to join Lesambah Transport Cooperative, Akira

and his partner Bernadette paid Panagsagan P29,000 for
documentation, P40,000 for “under the table” and P85,000 to include
another bus. Many times they asked for a refund as there was no
result. After he convinced them to join Sta. Monica Transport while
their Lesambah papers were pending, they paid him P200,000. He
notarized an “agreement” between them and Sta. Monica’s chairman
Rhoel. Later, they learned that Sta. Monica had long closed down. He
refused to return their money. Despite IBP notices, he failed to
answer or attend hearings. DISBARRED. His handling of his client’s
monies was condemnable. Canon 16, Rule 16.01, 16.02 and 16.03
explicit provide the rules on accounting of monies and properties
lawyers receive from their clients as well as their return upon
demand. The lawyer must properly account to the client on how
money received for a particular purpose was spent. He must return it
forthwith to the client if not used for the intended purpose. His failure
to render an account or return the money if the intended purpose
therefor does not materialize is a blatant disregard of Rule 16.01.
Yoshimura vs. Atty. Panagsagan, AC#10962, 9/11/2018
For their application to join Lesambah Transport Cooperative, Akira

and his partner Bernadette paid Panagsagan P29,000 for
documentation, P40,000 for “under the table” and P85,000 to include
another bus. Many times they asked for a refund as there was no
result. After he convinced them to join Sta. Monica Transport while
their Lesambah papers were pending, they paid him P200,000. He
notarized an “agreement” between them and Sta. Monica’s chairman
Rhoel. Later, they learned that Sta. Monica had long closed down. He
refused to return their money. Despite IBP notices, he failed to
answer or attend hearings. DISBARRED. His reprehensible conduct
of asking for P40,000 as “under the table” money was tantamount to
grave misconduct. Demanding money from his client purported as
bribe to expedite a transaction was an abuse of his client’s trust and
an overt act of undermining the public trust and faith in the
profession. As court officers, lawyers owe their utmost fidelity to
public service and administration of justice. A lawyer should not
indulge in any act that would damage public perception of
dispensation of justice.
Goopio vs. Atty. Maglalang, AC#10555, 7/31/2018
Cecilia was Maglalang’s former client. She introduced him to her

sister Goopio. To settle her realty contract dispute with a developer,
Goopio executed a power of attorney for Maglalang. She later
realized that she had been scammed into paying P484,000 for a
rescission case that was never filed. DISBARMENT COMPLAINT
DISMISSED. Goopio presented the power of attorney in the IBP
hearings along with the receipts he issued for the amounts received
as proof of their alleged attorney-client relationship. However,
submission of mere photocopies in evidence violates the best
evidence rule under Rule 130 (RC). Disbarment may not be akin to a
criminal prosecution but, if the entire body of proof consists mainly
of documentary evidence containing proof of either the falsity or
veracity of the charge, then the documents themselves, as submitted
into evidence must comply with the best evidence rule.
Yabut vs. Atty. Manalo, AC#10295, 8/30/2017
May accused Marissa of having an affair with her husband Ernie via
email. She submitted transcript of email exchanges between Marissa
and Ernie. Marissa denied the allegations. COMPLAINT DISMISSED.
Disciplinary proceedings are sui generis – neither purely civil nor
purely criminal. Still, compliance with basic rules of evidence may
not altogether be dispensed with. Evidence in consideration, i.e. the
transcript of email exchanges, failed to comply with the basic rule on
admissibility. Email exchanges are considered as electronic data
messages described in AM#01-7-01-SC (Rules on Electronic
Evidence) which regard electronic document as admissible in
evidence if it complies with the rules on admissibility prescribed by
the Rules of Court and related rules and authenticated in the manner
prescribed by the Rules on Electronic Evidence. Under the Rules of
Court, evidence is admissible when it is relevant to the issue and not
excluded by law. One rule in admitting evidence and avoiding
exclusion is to comply with the rules on authentication. In case of
electronic data, the manner in which such due execution and
authenticity are to be proved is specifically stated in Sec. 2, Rule 5 of
the Electronic Evidence Rule. Here, May only presented in evidence
transcripts of emails without proof of authentication. Hence, they
were inadmissible.
Yabut vs. Atty. Manalo, AC#10295, 8/30/2017
May complained that Marissa was having an affair with her husband
Ernie. She also questioned Marissa’s conduct as a lawyer for
allegedly posting indecent pictures on her social media account,
“Friendster.” Marissa argued that unconventional behavior is not
immoral conduct warranting disbarment. COMPLAINT DISMISSED.
Her act of posting her pictures, portraying herself in a seductive
manner, on her social media account was not grossly immoral. While
the kind of pictures which she posted do not exemplify and represent
how a lawyer, who is a court officer, must properly behave in the
public eye, still, it was not grossly immoral. Immoral conduct is that
which is so willful, flagrant or shameless as to show indifference to
the opinion of good and respectable members of the community.
Ignacio vs. Atty. Alviar, AC#11482, 7/17/2017
Alviar was paid P100,000 to defend Ignacio’s son. He had a 20-

minute meeting with the son at the PDEA center, got copies of the
case from the fiscal’s office, twice asked at the hall of justice if the
case was already filed and entered his appearance. Neither he nor
his proxy appeared during arraignment. He ignored her demand to
withdraw and partially return the fees. ORDERED TO RETURN
P97,000. Attorney’s fees is the reasonable compensation paid by a
client for the lawyer’s legal services. Acceptance fee is the charge
for merely accepting a case based on the preclusion from handling
opposing party’s cases once a laywer agrees to represent a client
due to the “conflict of interest” prohibition. The nature and extent of
services rendered does not measure acceptance fee. Such fee only
indemnifies the opportunity cost of mere acceptance. Alviar was
paid acceptance fee since Ignacio forthwith agreed and actually
paid. An order for the return of acceptance fee may be made when
the lawyer negligently handled the client’s case. The reasonable
amount of restitution would then be based on Quantum meruit. The
latter is a device to prevent undue enrichment based on the
equitable postulate that it is unjust for a person to retain benefit
without working for it. Alviar should be allowed P3,000 as reasonable
compensation for his efforts and for the particular circumstances in
the case.
Cabiles vs. Atty. Cedo, AC#10245, 8/16/2017
The appeal filed by Cabiles and her partners from a labor decision
was dismissed by the CA due to Cedo’s failure to post a bond.
Cabiles noted that Cedo did not write his MCLE Compliance in the
position paper and appeal memorandum. The MCLE Office certified
his non-compliance with the 1st, 2nd and 3rd MCLE Compliance
periods. SUSPENDED. He violated Canon 5 by not indicating his 3 rd
MCLE Compliance Number. BM#850 requires continuing legal
education as an added requisite for law practice to ensure that,
throughout their careers, lawyers keep abreast with law and
jurisprudence, maintain the profession’s ethics and enhance the
practice’s standards. A lawyer may be listed as a delinquent member
for non-compliance with the MCLE requirements.
Prosecutor Bacatan vs. Atty. Dadula, AC#10565, 9/7/2016
Dadula counter-sued for falsification after her client was accused of

libel. She later accused Bacatan of bias and partiality against her
client for finding probable cause for the libel but not for falsification
charge. She hinted that the fiscal was bribed. FINED. The adverse
resolution against her client prompted her to accuse Bacatan of
irregularity and bribery. If a lawyer’s strongly-worded statement
against opposing counsel is justified, disciplinary action is not
justified. Here, Dadula’s tirades were baseless. The prevailing NPS
practice is to ready the information along with the probable cause
resolution to facilitate case movement. Dadula could have easily
verified such practice which explained why the resolution and the
information had the same date before she condemned Bacatan. She
relied on her flimsy gut feeling and failed to substantiate her
allegations and sweeping conclusions. To accuse a lawyer wantonly
and maliciously of a serious misconduct absent any reasonable
cause is unethical. Bar membership imposes the obligation to be
honorable, candid and courteous in dealing with other lawyers and
to maintain fidelity to known and recognized Bar customs and
practices that make the practice a profession.
Prosecutor Bacatan vs. Atty. Dadula, AC#10565, 9/7/2016
Dadula counter-sued for falsification after her client was accused of

libel. She later accused Bacatan of bias and partiality against her
client for finding probable cause for the libel but not for falsification
charge. She hinted that the fiscal was bribed. FINED. When she
concluded based on gut feeling and without proof that Bacatan was
bribed, she overstepped the bounds of courtesy, candor and favor
Her attack on Bacatan’s character was completely unnecessary.
“Enthusiasm, or even excess of it, is not really bad.” One or the other
is no less a virtue if channeled in the right direction.” However, it
must be circumscribed within the bounds of propriety and with due
regard for the proper place of courts in our system of government.
Championing a client’s cause with zeal or enthusiasm is desirable
but unprofessional conduct coming from such zeal or enthusiasm is
disfavored.
Gimena vs. Atty. Sabio, AC#7178, 8/23/2016
Gimena was president and manager of Simon Peter Equipment. He

hired Sabio for an illegal dismissal case. Sabio filed the position
paper without signing it even after he was directed by the Arbiter.
Gimena only learned about the adverse decision when an execution
writ was served. SUSPENDED. His disobedience to the arbiter’s
directive to sign the position paper highlighted his inattention. Such
conduct evinced a willful disregard to his duty as a court officer. This
alone warranted the imposition of administrative liability.
Chang vs. Atty. Hidalgo, AC#6934, 4/6/2016
Chang paid Hidalgo for her collection cases. He did not attend
hearings. He later withdrew citing her uncooperative behavior.
SUSPENDED. His acts violated Canon 17 and Rule 18.03. Since
withdrawal was without her conformity, new counsel was not
engaged and the collection cases were summarily dismissed.
Client’s offensive attitude is not an excuse to just disappear and
withdraw from a case without notice to the court and to the client
more so when attorney’s fees have already been paid. A lawyer
cannot withdraw from a case without notice to the client and
compliance with the requirements of Sec. 26, Rule 138RC.
Gimena vs. Atty. Sabio, AC#7178, 8/23/2016
Gimena was president and manager of Simon Peter Equipment. He

hired Sabio for an illegal dismissal case. Sabio filed the position
paper without signing it even after he was directed by the Arbiter.
Gimena only learned about the adverse decision when an execution
writ was served. Sabio attributed his failure to inform Gimena about
the decision to the lack of a forwarding address. SUSPENDED. He
was fully aware of the company’s address as he himself notarized
Gimeno’s affidavit which was attached to the position paper. Said
affidavit clearly indicated the company’s address. Hence, he had no
justifiable reason not to notify Gimeno and the company of the
adverse decision. His conduct was inconsistent with Rule 18.04
which requires a lawyer to keep the client informed of case status
and to respond within a reasonable time to the client’s request for
information.
Sps. Jacinto vs. Atty. Bangot, AC#8494, 10/5/2016
A team tried to enter the property of Sps. Jacinto for a court-ordered

survey in a title reconstitution case. Bangot advised them to file a
certiorari petition to nullify the order and prevent further intrusions.
They signed a contract giving him a 250-sq. m. lot as attorney’s fees.
They offered to pay cash after they read and realized that the
contract allotted a different 300 sq. m. lot for his fees. He refused
and insisted he already filed a manifestation which assured that they
their possession would not be disturbed. SUSPENDED. At the start of
their relationship, he committed deceit by changing the property
ostensibly agreed upon with a bigger lot as payment for his fees. He
maintained this deceit by ultimately enforcing the contract against
them for specific performance. The totality of his actuations
inevitably eroded public trust in the Profession. On the basis of his
acts and actuations, his fees in the form of the lot he charged from
them were unconscionable and unreasonable, and should be struck
down for failing to pass muster under Rule 20.1.
Sanchez vs. Atty. Aguilos, AC#10543, 3/16/2016
Aguilos was paid to annul Sanchez’s marriage. Two months later, he

told her that legal separation due to psychological incapacity was
the proper action. He replied to her new lawyer’s demand for a
refund by describing her demand as a “scrap of paper or one that
new counsel who unskillfully relied on unverified information should
have addressed to MMDA’s urinal project.” ORDERED TO RETURN
THE MONEY. He should not have accepted the case as it was later
revealed that the case was way above his ability and competence.
He had no basis to accept any attorney’s fees from her. A lawyer
should have just and reasonable compensation in attorney’s fees for
services performed at his client’s special instance and request. He is
entitled to reasonable compensation as long as he is in good faith
and honestly trying to represent and serve the client’s interests.
Sanchez vs. Atty. Aguilos, AC#10543, 3/16/2016
Aguilos was paid to annul Sanchez’s marriage. Two months later, he

told her that legal separation due to psychological incapacity was
the proper action. He replied to her new lawyer’s demand for a
refund by describing her demand as a “scrap of paper or one that
new counsel who unskillfully relied on unverified information should
have addressed to MMDA’s urinal project.” REPRIMANDED AND
FINED. He committed an intolerable misconduct with his statement
about her demand. Canon 8 exhorts a lawyer to conduct himself with
courtesy, fairness and candor towards his colleagues and to avoid
harassing tactics against opposing counsel. Rule 18.01 specifically
enjoins him from from using abusive, offensive or otherwise
improper language in his professional dealings.
Sps. Jacinto vs. Atty. Bangot, AC#8494, 10/5/2016
A team tried to enter the property of Sps. Jacinto for a court-ordered

survey in a title reconstitution case. Bangot advised them to file a
certiorari petition to nullify the order and prevent further intrusions.
They signed a contract giving him a 250-sq. m. lot as attorney’s fees.
They offered to pay cash after they read and realized that the
contract allotted a different 300 sq. m. lot for his fees. He refused
and insisted he already filed a manifestation which assured that they
their possession would not be disturbed. SUSPENDED. At the time of
negotiations, he impressed upon them that his fees in the form of a
lot was on contingent basis. He misrepresented himself because the
contract’s express terms said that it would be effective immediately
upon signing and could not be revoked, amended or modified
without his consent. The contract, as worded, was not contingent. In
a contingent fee contract, the fee which is usually a fixed percentage
of what may be recovered in the case, depends upon the success in
enforcing or defending a supposed right. The amount of such fees
agreed upon by the parties is subject to the stipulation that counsel
will be paid for his legal services only if the suit prospers. Such
arrangement is generally recognized as valid and binding in this
jurisdiction but its terms must be reasonable.
Belo-Henares vs. Atty. Guevarra, AC#11394, 12/1/2016
Guevarra sued Vicky Belo, the Medical Director and Principal owner
of BELO MEDICAL GROUP, for botching his client’s buttocks
surgery. He took to Facebook (FB) and made maligning and insulting
posts such as “Quack Doctor Becky Belo; I am out to get Puwitic
Justice here! “You will go down in Medical History as a Quack
Doctor”, and “Reyna ng Kaplastikan, Reyna ng Kapalpakan.”
SUSPENDED. He violated Rule 7.03, 8.01 and 19.01 when he used
obscene and inappropriate language and publicly insulted and
undermined Belo’s reputation through FB posts. FB, as the most
popular social media site, has over 1 billion registered accounts with
1.71 billion monthly active users. He failed to offer evidence that his
posts were set to private view and that he utilized any FB privacy tool
or feature to protect his posts, or that he restricted its privacy to a
select few. Even restricting privacy of one’s posts to friends does not
guarantee absolute protection from the prying eyes of those who
may not belong to one’s circle of friends. The user’s own FB friends
can share said content or tag his/her own FB friends. Hence, his
claim of violation of right of privacy was negated. Freedom of speech
and expression, like all constitutional guarantees is not absolute. Her
status as a public figure and/or celebrity exposed to criticism did not
justify his disrespectful language. The cardinal condition of all
criticisms is that it must be bona fide and must not spill over the
walls of decency and propriety.
Re: March 17, 2011 Decision in Crim. Case No. SB-28361 (People vs.
Barrozo), AC#10207, 7/21/2015
Barrazo sent a demand letter to a client of Wats & Company of

Hongkong. Said company did an online search and read about his
bribery conviction with the Sandiganbayan for soliciting P20,000 for
a favorable resolution. Wats & Co. sent a letter asking the OBC if he
was still qualified to practice law. The Court motu proprio took up the
issue of his disbarment and required him to comment on why he
should not be suspended or disbarred due to his conviction. He
explained that signing the claim-letter was not law practice and no
money was involved since he signed out of his desire to only help.
DISBARRED. Whether signing the letter was law practice was not the
issue. The real issue was whether he should be suspended or
disbarred by reason of his conviction. Under Sec. 27, Rule 138,
conviction of a crime involving moral turpitude is a disciplinary
ground. With his final conviction, the next question that needed an
answer was whether direct bribery involved moral turpitude. It was
clearly a crime involving moral turpitude. However, conviction of a
crime involving moral turpitude does not ipso facto call for the
supreme penalty of disbarment to be imposed. The Court, in its
discretion, may opt to impose the less severe penalty of suspension.
Barrozo was an assistant prosecutor when he committed the crime.
His extortion violated the requirement that cases must be decided
based on the merits of the parties’ respective evidence. It lessened
the people’s confidence in the rule of law and showed his disregard
of his oath as a government official. Its nature also negatively
affected his qualifications as a lawyer.
Dalupan vs. Gacott, AC#5067, 6/29/2015
Dalupan paid Gacott P10,000 to defend her and her son from grave
slander and malicious mischief charges. She complained that he
refused to issue a receipt, failed to draft a bail reduction motion and
attend hearings. He claimed that he did file the motion but she got
mad when he refused her demand for him to negotiate with the judge
to insure bail reduction. He told her that he was a lawyer and not a
fixer. He pointed to non-receipt of notices, her termination of his
services and hiring of a new lawyer as reasons for his failure to
attend hearings. COMPLAINT DISMISSED. He was not bound to
return her money as he was neither at fault nor negligent in
performing his obligations under the retainer which she lawfully
ended due to trust and confidence. A distinction exists between
acceptance and attorney’s fees. In its ordinary sense, attorney’s
fees are the reasonable compensation the client pays for legal
services rendered. In its extraordinary concept, attorney’s fees are
the court award the losing party pays to the successful litigant for
damages. Acceptance fee is the charge for merely accepting the
case since agreeing to represent a client precludes a lawyer from
handling the opposing party’s cases due to the conflict of interest
rule. A lawyer incurs opportunity cost by merely accepting the
client’s case. This cost must be indemnified by payment of
acceptance fee. The nature and extent of legal services rendered
does not measure acceptance fee. The latter seeks only to
compensate the lawyer for lost opportunity.
Lingan vs. Atty. Calubaquib & Baliga, AC#5377, 6/30/2014
Baliga and Calubaquib were regional directors of the Commission on

Human Rights (CHR). They were both suspended from law practice
for violating the notarial law. A CHR resolution en banc suspended
them from their offices for want of eligibility while under law practice
suspension. Baliga filed a clarificatory pleading with the Court
insisting that his law suspension did not include suspension from
public office. Meanwhile, the CHR granted Baliga’s motion and,
instead of suspension from office, he was merely admonished.
SUSPENDED. He violated the Court’s suspension order. Law
practice is any activity in or out of court requiring application of law,
legal knowledge, training and experience. It includes performing
acts characteristic of the legal profession or rendering any kind of
service requiring the use in any degree of legal knowledge or skill.
Government work that requires use of legal knowledge is considered
law practice. A CHR regional director heads a regional office with
powers and functions characteristic of the legal profession. His
powers and functions constitute law practice. Thus, he must be an
attorney, i.e. a Bar member in good standing and authorized to
practice law. When he loses such authority, as when he is disbarred
or suspended from law practice, he loses a necessary qualification
to the position he is holding. The disbarred or suspended lawyer
must desist from holding the position of regional director.
Baens vs. Atty. Sempio, AC#10378, 6/9/2014
Baens paid Sempio P250,000 to nullify his marriage. Sempio failed to

file the petition. Baen’s wife filed a similar petition. Sempio belatedly
filed an answer without objecting to venue even though neither
spouse lived in Dasmarinas. He did not attend hearings and update
Baens on the wife’s petition. Baens filed a disbarment complaint. In
his answer, Sempio blamed Baen for the non-filing of his petition and
the delay in filing the answer. Baens allegedly took a long time to
read the petition and sign the verification. Sempio attributed his
failure to attend hearings to non-receipt of notices. SUSPENDED. His
excuse that he did not receive notices was intolerable. He had the
duty to execute all acts and procedures to advance his client’s cause
of action. As a lawyer, it was within his control and task to secure
copies of such notices, orders and case records. Preparation and
filing of the answer are procedural matters well-within a lawyer’s
exclusive control and responsibility.
Dizon vs. Atty. De Taza, AC#7676, 6/10/2014
De Taza was hired by Dizon and his siblings for a civil case. She
asked Dizon for P75,000 to expedite the case. Unknown to him, she
made a similar demand on his sister who actually paid P80,000. He
learned that the case was denied despite her claim that it was still
pending. He tried to contract her but she could not be found. He filed
a disbarment complaint attaching her other creditors’ affidavits.
Court resolutions for her to comment returned unserved even those
sent to her office and U.S. address. SUSPENDED. Her actuations
toward him and his siblings were worse since she had the gall to
make it appear that the case could be expedited and ruled in their
favor in exchange for an exorbitant amount. She employed such
scheme to milk more money from her clients. Her actions
undoubtedly were reprehensible. Her greed was more apparent
when she even used the court’s name to defraud her clients.
OCA vs. Atty. Melchor, Jr., AM#P-06-2227, 8/19/2014
Clerk of Court Melchor admitted the OCA findings of a P715,841

shortage in funds collected and unremitted cash bonds. He invoked
humanely error in discretion. He allegedly used the funds to pay his
child’s hospital bills. He prayed for humanitarian consideration and
compassion. He was already a municipal judge when he was found
guilty of dishonesty, gross neglect of duty and gross misconduct.
DISMISSED FROM SERVICE. Court personnel tasked with collection
of court funds, like a clerk of court, should deposit forthwith various
funds collected with the authorized government depositories.
Personal problems or even family medical emergencies do not justify
an accountable court officer’s use of judiciary funds.
De Leon vs. Atty. Pedrena, AC#9401, 10/22/2013
PAO lawyer Pedrena insisted that he and De Leon discuss her child
support case over lunch during which he kept asking her personal
questions. She accepted his ride offer but, while inside his car, he
pulled her close, rubbed her leg, tried to insert his finger into her
closed hand, grabbed and forcibly placed her hand on his crotch and
pressed his finger against her private part. SUSPENDED. The fact
that he was a Public Attorney aggravated his misconduct. As a PAO
lawyer, his mandate was to provide free legal service to indigent
litigants and she was such a client. He disregarded his Oath as a
public officer to serve others and to be accountable of her
vulnerability as a client then in despite need of his legal assistance.
Atty. Khan vs. Atty. Simbillo, AC#5299, 8/19/2003
Simbillo admitted to posting paid ads in 2 national newspapers. The

ads advertised his services as an “annulment of marriage specialist
at P48,000.00, within 4 to 6 months.” He insisted that advertising and
solicitation, per se, were not prohibited and that it was time to
change the view on such practices as an absolute ban on lawyer’s
advertising did not serve public interest. SUSPENDED. Law practice
is not a business but a profession in which duty to public service is
the primary consideration. Lawyering is not primarily meant to be a
money-making venture. Gaining a livelihood should be a secondary
consideration. Law advocacy is not a capital that necessarily yields
profits. Duty to public service and to administration of justice should
be the primary consideration of lawyers, who must subordinate their
personal interest or what they owe to themselves.
THE HARDEST CHOICES REQUIRES THE STRONGEST OF WILLS.
(thanos, Avengers “Infinity War”)

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UNIVERSITY OF SAN JOSE-RECOLETOS

LEGAL ETHICS CASE DIGEST

Buntag vs. Atty. Toledo, AC#12125, 2/11/2019

Buntag and his co-complainants were represented by Toledo in

Buntag vs. Atty. Toledo, AC#12125, 2/11/2019

Buntag and his co-complainants were represented by Toledo in

Concerned Students of Western Mindanao State University vs. Atty.

Law professor Esguerra was accused of sexually harassing or

Concerned Students of Western Mindanao State University vs. Atty.

Law professor Esguerra was accused of sexually harassing or

Sorensen vs. Atty. Pozon, AC#11334, 1/7/2019

Sorensen paid Pozon P72,000 to reconstitute a title, petition for

Sps. Frias vs. Atty. Abao, AC#12467, 4/10/2019

Escobar vs. Atty. Mercado, AC#11141, 8/7/2019

Escobar vs. Atty. Mercado, AC#11141, 8/7/2019

Sps. Asuncion vs. Atty. Bassig, AC#11830, 7/30/2019

Bassig, on Cabangon’s behalf, filed a complaint to annul a title. Sps.

Bassig, on Cabangon’s behalf, filed a complaint to annul a title. Sps.

Pacificar vs. Atty. Real, AC#9022, 6/10/2019

Dimaculangan vs. Attys. Jurado & Sta. Ana, AC#12359, 4/8/2019

Dimaculangan was talking to Jurado inside the courtroom waiting for

Sevilla vs. Atty. Millo, AC#10697, 3/25/2019

Sevilla was the publisher of the provincial newspaper Pampango

Bakidol vs. Atty. Bilog, AC#11174, 6/10/2019

Iglesia vs. Atty. Monsanto, AC#10597, 7/3/2019

Complainants were three police officers charged with multiple

Wilson vs. Atty. Lastimosa, AC#11153, 6/19/2019

Elsa sued Claude for legal separation. He in turn petitioned to nullify

Pacificar vs. Atty. Real, AC#9022, 6/10/2019

Huang vs. Atty. Zambrano, AC#12460, 3/26/2019

Turla vs. Atty. Caringal, AC#11641, 3/12/2019

Turla vs. Atty. Caringal, AC#11641, 3/12/2019

Angeles vs. Atty. Lina-ac, AC#12063, 1/8/2019

Angeles paid Lina-ac P50,000 to annul her marriage. After he gave

Sps. Zialcita vs. Atty. Latras, AC#7169, 3/11/2019

Spouses Zialcita allegedly sign an P11-million pacto de retro sale

Sps. Zialcita vs. Atty. Latras, AC#7169, 3/11/2019

Spouses Zialcita allegedly sign an P11-million pacto de retro sale

Basigsig vs. Atty. Aquino, AC#12362, 7/3/2019

Joey, an OFW in Korea, authorized Aquino to represent him in his

Sps. Regulto vs. Atty. Teoxon, AC#10301, 4/3/2019

Spouses Regulto were the respondents in a certiorari petition. The

Justice Peralta vs. Atty. Ramon, AC#12415, 3/5/2019

Tabao vs. Atty. Lacaba, AC#9269, 3/13/2019

Tabao accused Lacaba of notarizing the counter-affidvit to the

Atty. Agustin vs. Atty. Laeno, AC#8124, 3/19/2019

Agustin’s sister represented their mother in buying a house and lot

Fr. Zafra vs. Atty. Pagatpatan, AC#12457, 4/2/2019

Pagatpatan wrote the Bishop of Tandag to investigate Zafra’s

Fr. Zafra vs. Atty. Pagatpatan, AC#12457, 4/2/2019

Pagatpatan wrote the Bishop of Tandag to investigate Zafra’s

Salazar vs. Atty. Quiambao, AC#12401, 3/12/2019

Chan vs. Atty. Cabrera, AC#10439, 9/3/2019

Chan vs. Atty. Cabrera, AC#10439, 9/3/2019

Yap vs. Atty. Dantes, AC#11741, 6/19/2019

Anima vs. Prosecutor Penaco-Rojas, AC#10121, 4/1/2019

Muntuerto vs. Atty. Alberto, AC#12289, 4/2/2019

Alberto, as Dinopol’s counsel, filed a recovery complaint against

Muntuerto vs. Atty. Alberto, AC#12289, 4/2/2019

Alberto, as Dinopol’s counsel, filed a recovery complaint against

Achacoso vs. Judge Garces, AM#MTJ-19-1923, 9/4/2019

Marapao was Nimfa’s counsel in criminal cases against Lorgina. He

Achacoso vs. Judge Garces, AM#MTJ-19-1923, 9/4/2019