Professional Documents
Culture Documents
RESOLUTION
VILLARAMA, JR. , J : p
While most agree that the right to criticize the judiciary is critical to maintaining a
free and democratic society, there is also a general consensus that healthy criticism only
goes so far. Many types of criticism leveled at the judiciary cross the line to become
harmful and irresponsible attacks. These potentially devastating attacks and unjust
criticism can threaten the independence of the judiciary. 4 The court must "insist on
being permitted to proceed to the disposition of its business in an orderly manner, free
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from outside interference obstructive of its functions and tending to embarrass the
administration of justice." 5
The Court could hardly perceive any reasonable purpose for the faculty's less than
objective comments except to discredit the April 28, 2010 Decision in the Vinuya case
and undermine the Court's honesty, integrity and competence in addressing the motion
for its reconsideration. As if the case on the comfort women's claims is not controversial
enough, the UP Law faculty would fan the ames and invite resentment against a
resolution that would not reverse the said decision. This runs contrary to their obligation
as law professors and o cers of the Court to be the rst to uphold the dignity and
authority of this Court, to which they owe delity according to the oath they have taken
as attorneys, and not to promote distrust in the administration of justice. 6 Their actions
likewise constitute violations of Canons 10, 11, and 13 7 and Rules 1.02 and 11.05 8 of
the Code of Professional Responsibility. 9
WHEREFORE , in light of the foregoing, Attys. Marvic M.V.F. Leonen, Froilan M.
Bacungan, Paci co A. Agabin, Merlin M. Magallona, Salvador T. Carlota, Carmelo V. Sison,
Patricia R.P. Salvador Daway, Dante B. Gatmaytan, Theodore O. Te, Florin T. Hilbay, Jay L.
Batongbacal, Evelyn (Leo) D. Battad, Gwen G. De Vera, Solomon F. Lumba, Rommel J.
Casis, Jose Gerardo A. Alampay, Miguel R. Armovit, Arthur P. Autea, Rosa Maria J.
Bautista, Mark R. Bocobo, Dan P. Calica, Tristan A. Catindig, Sandra Marie O. Coronel,
Rosario O. Gallo, Concepcion L. Jardeleza, Antonio G.M. La Viña, Carina C. Laforteza, Jose
C. Laureta, Owen J. Lynch, Rodolfo Noel S. Quimbo, Antonio M. Santos, Gmeleen Faye B.
Tomboc, Nicholas Felix L. Ty, Evalyn G. Ursua, Raul V. Vasquez, Susan D. Villanueva, and
Dina D. Lucenario, members of the faculty of the University of the Philippines College of
Law, are directed to SHOW CAUSE , within ten (10) days from receipt of a copy of this
Resolution, why they should not be disciplined as members of the Bar for violation of
Canons 10, 11, and 13 and Rules 1.02 and 11.05 of the Code of Professional
Responsibility.
Further, Dean Marvic M.V.F. Leonen is directed to SHOW CAUSE, within ten (10)
days from receipt of this Resolution, why he should not be disciplinarily dealt with for
violation of Canon 10, Rules 10.01, 10.02 and 10.03 for submitting, through his letter
dated August 10, 2010, during the pendency of G.R. No. 162230, Vinuya v. Executive
Secretary and of the investigation before the Committee on Ethics and Ethical Standards,
for the consideration of the Court En Banc, a dummy which is not a true and faithful
reproduction of the purported statement, entitled "Restoring Integrity: A Statement by
the Faculty of the University of the Philippines College of Law on the Allegations of
Plagiarism and Misrepresentation in the Supreme Court." Enclosed are copies of the said
dummy and signed statement, respectively, attached to the said letter dated August 10,
2010 and to the Compliance dated August 31, 2010 led by Roque & Butuyan Law
Offices with the Committee on Ethics and Ethical Standards. cDTIAC
Separate Opinions
CARPIO MORALES , J., dissenting :
The Resolution directs certain members of the law faculty of the University of the
Philippines (UP) to "SHOW CAUSE . . . why they should not be disciplined as members of
the Bar for violation of Canons 1, 11 and 13 and Rules 1.02 and 11.05 of the Code of
Professional Responsibility." 1
The Resolution demonstrates nothing but an abrasive exing of the judicial muscle
that could hardly be characterized as judicious. This knee-jerk response from the Court
stares back at its own face, since this judicial act is the one that is "totally unnecessary,
uncalled for and a rash act of misplaced vigilance." 2
The road embarked by the Court as paved by the Resolution leads the Court into
an autocratic pit with only an arti cial twig of "independence of the judiciary" to hang on
to somewhere in that precarious cliff where public esteem shall ultimately reckon what
"dignity of the Court" means. I regret that I could not join in treading such crooked road.
The institution of a disciplinary action
smacks of injudiciousness
In instituting the proceedings 3 against the UP law faculty, the Court appears to be
lending only a semblance of due process by ordering them to answer the administrative
charges. The Resolution is replete with conclusions that already adjudge them guilty of
violating the canons of ethics. Aside from concluding that the publication of the
statement of the UP law faculty was "totally unnecessary, uncalled for and a rash act of
misplaced vigilance," the Resolution classi es it as an "institutional attack" and an "insult
to the members of the Court." 4 The Court has already determined that it "could hardly
perceive any reasonable purpose for the faculty's less than objective comments" 5 that
"fan the ames and invite resentment." 6 The adverse declarations describing the written
work of the UP law faculty operate to their prejudice since that would render any
subsequent proceeding illusory, because the Court, which would ultimately decide the
administrative case, has already made up its mind even before hearing the parties. HEcIDa
Worse, the Resolution is not what it purports to be. Ostensibly, the Resolution is a
show cause order that initiates what would become a newly docketed regular
administrative matter. There is more than meets the eye, however. When stripped of its
apparent complexion, the Resolution shows its true colors and presents itself as a
pronouncement of guilt of indirect contempt, without proper recourse left to the parties.
Without the bene t of a hearing and extensively quoting cases involving contempt, the
Resolution admonishes:
. . . We made it clear in the case of In re Kelly that any publication, pending a
suit, re ecting upon the court, the jury, the parties, the o cers of the court, the
counsel with reference to the suit, or tending to in uence the decision of the
controversy, is contempt of court and is punishable.
While most agree that the right to criticize the judiciary is critical to
maintaining a free and democratic society, there is also a general consensus that
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healthy criticism only goes so far. Many types of criticism leveled at the judiciary
cross the line to become harmful and irresponsible attacks. These potentially
devastating attacks and unjust criticism can threaten the independence of the
judiciary. The Court must "insist on being permitted to proceed to the disposition of
its business in an orderly manner, free from outside interference obstructive of its
functions and tending to embarrass the administration of justice." 7
Although as a human being, a person naturally gets pissed off by hurtful words, it
would not hurt the Court as an institution and the law as a profession if it passes off the
statement of the UP law faculty at this time.
With all due respect to my colleagues, it is not the place of the Court to seek
revenge against those who, in their wish to see reform in the judiciary, have the courage
to say what is wrong with it. The Court nds its legitimacy in demonstrating its moral
vein case after case, not in aunting its judicial brawn. There is nothing to be gained for
the administration of justice in not letting this one instance pass just because feelings
have been hurt and the urge to retaliate must be satis ed. If the 37 members of the UP
Law Faculty are wrong, there will be recompense in their loss of esteem among the
academic community and the legal profession. But if they are right, then the Court will
have made martyrs out of those who — in their temporary passion — may have acted
recklessly but truthfully and sincerely. Indeed, should they be proven right, they may even
rise in esteem in the eyes of international academic and legal circles, for being the object
of prosecution by one's Supreme Court for bold but intelligent reformist language can be
deemed a badge of honor similar to that bequeathed by history to the great thinkers who
were persecuted by society's reactionary forces.
Indirect contempt is committed in any of the acts enumerated in Section 3, Rule
71 of the Rules of Court. The majority Resolution, which is the written charge required by
said rule, fails to cite which particular mode of committing indirect contempt appears to
have been violated. It is axiomatic to due process that the accused be informed
speci cally of the charge against them. A proceeding for indirect contempt is criminal in
nature; thus, adherence to due process is more stringently required of this Court.
From a reading of the majority Resolution, it can be inferred that the following
constitute the portions of the text of the UP Law Faculty Statement that draw the charge
of indirect contempt: (a) the accusation that "an extraordinary act of injustice has been
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committed against the brave Filipinas who suffered abuse during a time of war"; (b) the
casting of the decision as "a reprehensible act of dishonesty and misrepresentation by
the Highest Court of the land"; (c) the further attempt to educate the Court on how to go
about the review of the case; (d) imputations of deliberately delaying the resolution of
the Vinuya case; (e) the dismissal of the petition on the basis of "polluted sources"; (f)
alleged indifference to the cause of petitioners; (g) the supposed alarming lack of
concern of the members of the Court for even the most basic values of decency and
respect. The majority Resolution believes that the UP Law Faculty's comments have no
purpose other than to "discredit the April 28, 2010 Decision in the Vinuya case and
undermine the Court's honesty, integrity and competence in addressing the
motion for its reconsideration." (Emphasis supplied.)
Despite the description of what it considers the allegedly offending language of
the Faculty Statement, the majority Resolution must still identify the speci c paragraph
of Section 3, Rule 71 of which the UP Law Faculty appears guilty and must not leave it to
the reader to infer the basis of the complaint for indirect contempt.TAHcCI
Neither can I agree that Dean Marvic Leonen should be asked to show cause why
he should not be punished for sending the Chief Justice mere dummies of the statement.
In most cases, this Court merely gives the parties' counsel the opportunity to satisfy the
missing requirements. In any case, he has already submitted the signed original
statement, so what is the Court fretting over? This use of a heavy hand on a small matter
is profoundly disturbing.
The reason, I think, is that this Court has already prejudged the respondents.
Reviewing the events, I realize that the language used in the majority Decision in the
matter of the plagiarism charges, 2 and the circumstances under which this "show cause"
order is being issued, paint a chilling picture of the Court. When the UP Law Faculty
statement was issued, the Court was taken aback, teetering a little from the blast of
what they thought was the power of 81 signatures of the UP Law Faculty, including that
of a retired justice. Then it found out that Dean Leonen, when ordered, was actually ready
to transmit a statement with only 37 signatures. The Court recovered its composure and
seethed that it could have been so destabilized. This turn of events may account for the
victorious tone used by the plagiarism majority Decision when it referred to the UP Law
Faculty Statement as a statement that had "appeared like solid teeth in the dummy [but]
turned out to be broken teeth in the original . . . [a]nd retired Justice V.V. Mendoza did not
sign the statement, contrary to what the dummy represented." It seems to have gloated
over the realization that now the antagonist is more manageable, consisting only of
these 37 law professors, sans any retired Supreme Court justice. With more reason
should the Court evaluate its mental and emotional frame before issuing the "show
cause" order. Is it ready to squarely face the fact that the moral consequences of the
plagiarism majority Decision are too horrible to imagine?
The timing of the "show cause" order; the implication in the related Decision 3 that
the complainants in the plagiarism charge against Justice del Castillo are "hypocrites";
the needling over a small matter such as submission of a dummy vis-Ã -vis the original
signed copies; and the apparent effect that the submission of the Statement had on the
Court — all of these betray a Court that is bent on seeing itself redeemed not by hard and
honest work, with the undertaking of proper remedial actions for when a member is in
breach of ethics, but by showing who, in the land of lawyers, has power.
It is with sadness that I view the issuance of the "show cause" order embodied in
the majority Resolution and dissent therefrom.
ATTACHMENT
UNIVERSITY OF THE PHILIPPINES
COLLEGE OF LAW
Malcom Hall, Diliman, Quezon City 1101, Philippines
Tel. 920-5514 local 101/102; Telefax 927-0518
Marvic M.V.F. Leonen
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Dean and Professor of Law
August 10, 2010
The Honorable
Supreme Court of the Republic of the Philippines
Through:Hon. Renato C. Corona
Chief Justice
Subject:Statement of faculty
from the UP College of Law
on the Plagiarism in the case of
Vinuya v. Executive Secretary
Your Honors:
We attach for your information and proper disposition a statement signed by thirty eight
(38) members of the faculty of the UP College of Law. We hope that its points could be considered
by the Supreme Court en banc.
Respectfully,
(SGD.) Marvic M.V.F.
Leonen
Dean and Professor of Law
RESTORING INTEGRITY
The Court cannot regain its credibility and maintain its moral authority without ensuring that its
own conduct, whether collectively or through its Members, is beyond reproach. This necessarily
includes ensuring that not only the content, but also the processes of preparing and writing its
own decisions, are credible and beyond question. The Vinuya Decision must be conscientiously
reviewed and not casually cast aside, if not for the purpose of sanction, then at least for the
purpose of re ection and guidance. It is an absolutely essential step toward the establishment
of a higher standard of professional care and practical scholarship in the Bench and Bar, which
are critical to improving the system of administration of justice in the Philippines. It is also a
very crucial step in ensuring the position of the Supreme Court as the Final Arbiter of all
controversies: a position that requires competence and integrity completely above any and all
reproach, in accordance with the exacting demands of judicial and professional ethics.
With these considerations, and bearing in mind the solemn duties and trust reposed upon them
as teachers in the profession of Law, it is the opinion of the Faculty of the University of the
Philippines College of Law that:
(1) The plagiarism committed in the case of Vinuya v. Executive Secretary is
unacceptable, unethical and in breach of the high standards of moral
conduct and judicial and professional competence expected of the Supreme
Court;
(2) Such a fundamental breach endangers the integrity and credibility of the
entire Supreme Court and undermines the foundations of the Philippine
judicial system by allowing implicitly the decision of cases and the
establishment of legal precedents through dubious means;
(3) The same breach and consequent disposition of the Vinuya case does
violence to the primordial function of the Supreme Court as the ultimate
dispenser of justice to all those who have been left without legal or equitable
recourse, such as the petitioners therein;
(4) In light of the extremely serious and far-reaching nature of the dishonesty
and to save the honor and dignity of the Supreme Court as an institution, it
is necessary for the ponente of Vinuya v. Executive Secretary to resign his
position, without prejudice to any other sanctions that the Court may
consider appropriate; SICaDA
(5) The Supreme Court must take this opportunity to review the manner by
which it conducts research, prepares drafts, reaches and nalizes decisions
in order to prevent a recurrence of similar acts, and to provide clear and
concise guidance to the Bench and Bar to ensure only the highest quality of
legal research and writing in pleadings, practice, and adjudication.
Malcolm Hall, University of the Philippines College of Law, Quezon City, 27 July 2010.
(SGD.) MARVIC M.V.F. LEONEN
Dean and Professor of Law
(SGD.) FROILAN M. BACUNGAN (SGD.) PACIFICO A. AGABIN
Dean (1978-1983) Dean (1989-1995)
(SGD.) MERLIN M. MAGALLONA (SGD.) SALVADOR T. CARLOTA
Dean (1995-1999) Dean (2005-2008)
and Professor of Law
REGULAR FACULTY
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(SGD.) CARMELO V. SISON (SGD.) JAY L. BATONGBACAL
Professor Assistant Professor
(SGD.) PATRICIA R.P. SALVADOR (SGD.) EVELYN (LEO) D. BATTAD
DAWAY Assistant Professor
Associate Dean and Associate Professor
(SGD.) DANTE B. GATMAYTAN (SGD.) GWEN G. DE VERA
Associate Professor Assistant Professor
(SGD.) THEODORE O. TE (SGD.) SOLOMON F. LUMBA
Assistant Professor Assistant Professor
(SGD.) FLORIN T. HILBAY (SGD.) ROMMEL J. CASIS
Assistant Professor Assistant Professor
LECTURERS
(SGD.) JOSE GERARDO A. ALAMPAY (SGD.) JOSE C. LAURETA
(SGD.) ARTHUR P. AUTEA (SGD.) DINA D. LUCENARIO
(SGD.) ROSA MARIA J. BAUTISTA (SGD.) OWEN J. LYNCH
(SGD.) MARK R. BOCOBO (SGD.) ANTONIO M. SANTOS
(SGD.) DAN P. CALICA (SGD.) VICENTE V. MENDOZA
(SGD.) TRISTAN A. CATINDIG (SGD.) RODOLFO NOEL S. QUIMBO
(SGD.) SANDRA MARIE O. CORONEL (SGD.) GMELEEN FAYE B. TOMBOC
(SGD.) ROSARIO O. GALLO (SGD.) NICHOLAS FELIX L. TY
(SGD.) CONCEPCION L. JARDELEZA (SGD.) EVALYN G. URSUA
(SGD.) ANTONIO G.M. LA VIÑA (SGD.) RAUL T. VASQUEZ
(SGD.) CARINA C. LAFORTEZA (SGD.) SUSAN D. VILLANUEVA
Email: mail@roquebutuyan.com
Fax No: 887-3893
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UNIVERSITY OF THE PHILIPPINES
COLLEGE OF LAW
RESTORING INTEGRITY
It is within this frame that the Faculty of the University of the Philippines College of Law views
the charge that an Associate Justice of the Supreme Court committed plagiarism and
misrepresentation in Vinuya v. Executive Secretary . The plagiarism and misrepresentation are
not only affronts to the individual scholars whose work have been appropriated without correct
attribution, but also a serious threat to the integrity and credibility of the Philippine Judicial
System.
In common parlance, 'plagiarism' is the appropriation and misrepresentation of another
person's work as one's own. In the eld of writing, it is cheating at best, and stealing at worst. It
constitutes a taking of someone else's ideas and expressions, including all the effort and
creativity that went into committing such ideas and expressions into writing, and then making
it appear that such ideas and expressions were originally created by the taker. It is dishonesty,
pure and simple. A judicial system that allows plagiarism in any form is one that allows
dishonesty. Since all judicial decisions form of the law of the land, to allow plagiarism in the
Supreme Court is to allow the production of laws by dishonest means. Evidently, this is a
complete perversion and falsification of the ends of justice.
A comparison of the Vinuya decision and the original source material shows that the ponente
merely copied select portions of other legal writers' works and interspersed them into the
decision as if they were his own, original work. Under the circumstances, however, because the
Decision has been promulgated by the Court, the Decision now becomes the Court's and no
longer just the ponente's. Thus the Court also bears the responsibility for the Decision. In the
absence of any mention of the original writers' names and the publications from which they
came, the thing speaks for itself.
So far there have been unsatisfactory responses from the ponente of this case and the
spokesman of the Court. TcIaHC
It is argued, for example, that the inclusion of the footnotes from the original articles is a
reference to the 'primary' sources relied upon. This cursory explanation is not acceptable,
because the original authors' writings and the effort they put into nding and summarizing
those primary sources are precisely the subject of plagiarism. The inclusion of the footnotes
together with portions of their writings in fact aggravates, instead of mitigates, the plagiarism
since it provides additional evidence of a deliberate intention to appropriate the original
authors' work of organizing and analyzing those primary sources.
(2) Such a fundamental breach endangers the integrity and credibility of the
entire Supreme Court and undermines the foundations of the Philippine
judicial system by allowing implicitly the decision of cases and the
establishment of legal precedents through dubious means;
(3) The same breach and consequent disposition of the Vinuya case does
violence to the primordial function of the Supreme Court as the ultimate
dispenser of justice to all those who have been left without legal or equitable
recourse, such as the petitioners therein;
(4) In light of the extremely serious and far-reaching nature of the dishonesty
and to save the honor and dignity of the Supreme Court as an institution, it
is necessary for the ponente of Vinuya v. Executive Secretary to resign his
position, without prejudice to any other sanctions that the Court may
consider appropriate;
(5) The Supreme Court must take this opportunity to review the manner by
which it conducts research, prepares drafts, reaches and nalizes decisions
in order to prevent a recurrence of similar acts, and to provide clear and
concise guidance to the Bench and Bar to ensure only the highest quality of
legal research and writing in pleadings, practice, and adjudication.
Malcolm Hall, University of the Philippines College of Law, Quezon City, 27 July 2010.
(SGD.) MARVIC M.V.F. LEONEN
Dean and Professor of Law
(SGD.) FROILAN M. B ACUNGAN BARTOLOME S. CARALE (SGD.) PACIFICO A. AGABIN
Dean (1978-1983) Dean (1983-1989) Dean (1989-1995)
(SGD.) MERLIN M. MAGALLONA RAUL C. PANGALANGAN (SGD.) SALVADOR T.
CARLOTA
Dean (1995-1999) Dean (1999-2005) Dean (2005-2008)
and Professor of Law and Professor of Law
REGULAR FACULTY
(SGD.) CARMELO V. SISON
Professor
EDUARDO A. LABITAG (SGD.) FLORIN T. HILBAY
Professor Assistant Professor
ELIZABETH A. PANGALANGAN JOSE JESUS M. DISINI, JR.
Professor Assistant Professor
DANILO L. CONCEPCION HERMINIO HARRY L. ROQUE, JR.
Associate Professor Assistant Professor
VIRGILIO S. JACINTO (SGD.) JAY L. BATONGBACAL
Associate Professor Assistant Professor
(SGD.) PATRICIA R.P. SALVADOR (SGD.) EVELYN (LEO) D. BATTAD
DAWAY
Associate Dean and Associate Professor Assistant Professor
(SGD.) DANTE B. GATMAYTAN (SGD.) IBARRA M. GUTIERREZ III
Associate Professor Assistant Professor
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VICTORIA A. AVENA (SGD.) GWEN G. DE VERA
Associate Professor Assistant Professor
ROWENA D. MORALES (SGD.) SOLOMON F. LUMBA
Assistant Professor Assistant Professor
(SGD.) THEODORE O. TE (SGD.) ROMMEL J. CASIS
Associate Professor Assistant Professor
LECTURERS
(SGD.) JOSE GERARDO A. ALAMPAY DOMINGO P. DISINI, JR.
VICENTE B. AMADOR RAQUEL D.R. FORTUN
(SGD.) MIGUEL R. ARMOVIT (SGD.) ROSARIO O. GALLO
(SGD.) ARTHUR P. AUTEA ROWENA V. GUANZON
RUBEN F. BALANE MA. TERESITA J. HERBOSA
CHRYSILLA CARISSA P. BAUTISTA (SGD.) CONCEPCION L. JARDELEZA
MANUEL P. BAUTISTA, JR. ILDEFONSO R. JIMENEZ
(SGD.) ROSA MARIA J. BAUTISTA MARK DENNIS Y. JOVEN
ARACELI T. BAVIERA (SGD.) ANTONIO G.M. LA VIÑA
(SGD.) MARK R. BOCOBO (SGD.) CARINA C. LAFORTEZA
(The theft of a man's thoughts is a
grosser
crime than the theft of a man's goods.)
(SGD.) DAN P. CALICA (SGD.) JOSE C. LAURETA
OTHELO C. CARAG JOSE M. LAYUG, JR.
(SGD.) TRISTAN A. CATINDIG MA. CAROLINA T. LEGARDA
(SGD.) SANDRA MARIE O. CORONEL CARLOS ROBERTO Z. LOPEZ
MONALISA C. DIMALANTA ELIZABETH P. LORIEGA
(SGD.) OWEN J. LYNCH DIONNE MARIE M. SANCHEZ
VICTORINO C. MAMALATEO JANUARY A. SANCHEZ
(SGD.) VICENTE V. MENDOZA ARNO V. SANIDAD
ALFREDO B. MOLO III (SGD.) ANTONIO M. SANTOS
RAFAEL A. MORALES FRANCIS V. SOBREVIÑAS
ALBERTO T. MUYOT, JR. MARY ROSE S. TAN
(SGD.) RODOLFO NOEL S. QUIMBO (SGD.) GMELEEN FAYE B. TOMBOC
MARIE CECILE R. QUINTOS (SGD.) NICHOLAS FELIX L. TY
MA. GISELLA D. REYES (SGD.) EVALYN G. URSUA
ROCKY D.L. REYES (SGD.) RAUL T. VASQUEZ
MEHOL K. SADAIN (SGD.) SUSAN D. VILLANUEVA
AUGUSTO A. SAN PEDRO ROGELIO A. VINLUAN
Footnotes
1.Black, Henry Campbell, BLACK'S LAW DICTIONARY, 5th ed., St. Paul Minn., West Publishing
Co., 1979, p. 1035.
2.Executive Secretary Alberto G. Romulo, Secretary of Foreign Affairs Delia Domingo-Albert,
Secretary Merceditas N. Gutierrez, and Solicitor General Alfredo L. Benipayo.
6.Id.
7.CANON 10 — A lawyer shall uphold the constitution, obey the laws of the land and promote
respect for law and for legal processes.
CANON 11 — A lawyer shall observe and maintain the respect due to the Courts and to
judicial officers and should insist on similar conduct by others.
CANON 13 — A lawyer shall rely upon the merits of his cause and refrain from any
impropriety which tends to influence, or gives the appearance of influencing the Court.
8.Rule 1.02 — A lawyer shall not counsel or abet activities aimed at de ance of the law or at
lessening confidence in the legal system.
Rule 11.05 —A lawyer shall submit grievances against a judge to the proper authorities
only.
9.Promulgated by this Court on June 21, 1988.
2.Id. at 3.
3.Under Rule 139-B of the Rules of Court.
4.Resolution, p. 2.
5.Id. at 3.
6.Id. at 4.
7.Id. at 3.
8.Ceniza v. Wistehuff, Sr., G.R. No. 165734, June 16, 2006, 491 SCRA 148, 165, citing
Montenegro v. Montenegro, G.R. No. 156829, June 8, 2004, 431 SCRA 415.
9.Vda de Victoria v. Court of Appeals, G.R. No. 147550, August 16, 2005, 467 SCRA 78, 88.
10.Ex parte Steinman [1880], 40 Am. Rep. 637, cited in the Dissenting Opinion of Justice George
Malcolm in Salcedo v. Hernandez, 61 Phil. 724 (1935); and in In re: Almacen, 142 Phil. 353
(1970).
11.Resolution, p. 2.
1.In the Matter of the Charges of Plagiarism, Etc., Against Associate Justice Mariano C. Del
Castillo (In the Matter of the Charges of Plagiarism), AM 10-7-17-SC, October 12, 2010.
2.In the Matter of the Charges of Plagiarism, supra note 1.
3.Id.