Dallong-Galicinao vs.

Castro

Facts: Atty. Castro, a private practitioner, went to the office of Atty. Dallong-Galicinao, the clerk
of court of Bambang (Nueva Vizcaya) RTC, to inquire whether the complete records of a civil
case had already been remanded to the court of origin. Atty. Castro was not the counsel of
record of either party in the said civil case. When denied such request, Atty. Castro hurled
invectives at Atty. Dallong-Galicinao which caused the same to file a complaint-affidavit against
the former for unprofessional conduct. Due to Atty. Castro’s public apology, Atty. Dallong-
Galicinao expressed her desire not to appear on the next hearing.

Issue: Whether or not Atty. Castro should be held administratively liable.

Decision: Yes. Not being the counsel of record and there being no authorization from either the
parties to represent them, Atty. Castro has no right to impose his will on the clerk of court.
Although the penalty should be tempered since Atty. Castro apologized and Atty. Dallong-
Galicinao accepted it. This is not to say that Atty. Castro should be absolved of his actuations.
Atty. Castro is ordered fined in the amount of P10,000.00 with a warning that any similar
infractions shall be dealt with more severely.