R

fwCriticism against judges/courts

One of the issues confronting a Philippine lawyer today is up to what extent can he
exercise his right to free speech and expression in ventilating his cause whenever the ruling of a
judge or court does not conform with the result he or his client expects in the light of his
performance before the bar. Whether one takes the plaintiff s or defendants side, the mettle of
a practitioner is always put to test each time or particularly when the judge or court reacts during
the proceedings up to the resolution of a case. For one thing, the guiding principle of law of the
lower court would always be the pronouncements of the Supreme Court. In the American
setting where the legal system can already be seen as being a mature legal system, with a more
than 200 year-old constitution that has undergone 37 amendments, the first 10 having been
ratified simultaneously in 17911, the provision on freedom of speech which has always stood as
the First Amendment may be a legal pattern for the Filipino lawyer. While most Americans
today take their First Amendment rights for granted, the experiences of the colonists in the 1760s
and 1770s made them wary of the new government created by the Constitution. Consequently, it
was important to them to have a clearly written statement of the rights on which the government
could not infringe. While the expression rights guaranteed by the First Amendment are
straightforward on paper, xxx their interpretation has not always been easy. Surely the Framers
did not mean that anyone could say anything they wanted to or express themselves in any way
they chose at any time in any place. While the First Amendment says that the "Congress shall
make no law" limiting the freedom of speech, very few people believe that the rights listed in it
were meant to be absolute. Xxx but where should the lines between acceptable and unacceptable
forms of expression be drawn? Once again, it would fall to the Supreme Court to decide 2.
Thus, in the same manner, we can always look back to the decisions handed down by our own
High Court.
Lawyers have the duty to respect courts and judicial officers. They are expected to
maintain respect and insist on similar conduct by others. They are duty bound to uphold the
dignity and authority of the court to which they owe fidelity 3. On the other hand, lawyers are
given the right to criticize judicial conduct. The constitutional guaranty that No law shall be
passed abridging the freedom of speech, of expression, or of the press, or the right of the people
to peaceably assemble and petition the government for redress of grievances. has application to
lawyers. We now seek to find out to what extent can lawyers exercise their freedom of speech
and expression in relation to the courts and the options open to them in seeking redress for
their grievances against a judge or the courts.
1

Answers.com Wikianswer, January 10, 2011

This Nation.com, Internet, January 9, 2011

In re: Sotto, 82 Phil Reports 595

The Concept of Criticism

Criticism of court is not per se contemptuous. It can be considered as constructive, the
purpose of which is to timely correct/rectify a mistake, error, or irregularity so that true justice
may be achieved. It is therefore, an essential ingredient in the administration of justice and in
adherence to law. It is an adverse analysis of an order, judgment or a judicial act of a magistrate
to prevent or avoid incipient injustice arising from pernicious effects of the mistake, error or
irregularity committed fidelity. The guarantee of free speech include the right to criticize judicial
conduct. Nevertheless, the constitutional freedom of free speech cannot shield the erring lawyer
from the punishing hand of the court to preserve and enforce its order in its immediate presence.4
The following case laws are to us illuminating.

A. ERRING LAWYERS CAN NOT INVOKE PROTECTED SPEECH

In re Cobb
445 Mass. 452, 838 N.E.2d 1197 (2005)
The respondent, Matthew Cobb, appeals from the judgment of a single justice disbarring
him from the practice of law for multiple violations of the Massachusetts Rules of Professional
Conduct and the former Canons of Ethics and Disciplinary Rules in three cases consolidated for
hearing by the Board of Bar Overseers. Cobb came out with statements impugning the integrity
of judges. In the first case, the respondent was found to have filed a motion containing
improbable and false allegations , thereby exposing his client to sanctions. He also made
groundless representations to the judge. In the second case, the respondent charged that the
Superior Court judge who had sanctioned him had been improperly influenced and was biased. In the
third case, the respondent settled a client's case without her authority. Additionally, he continued to
represent her when their interests were in conflict, purportedly disclosed privileged client
communications without authorization, and made misrepresentations to a judge and to bar counsel.
ISSUE
WON a lawyer may be spared from disbarment on the ground that his speech is constitutionally
protected under the First Amendment.

Ernesto Pineda, AA,AB, LLB; The Lawyer and the Courts, Judicial and Legal Ethics, 2010 ed.

The respondent contends that two statements he made involve public speech on matters of the
highest public concern, namely, corruption by public officials, and as such constitute protected speech.
RULING
The respondent has demonstrated rather convincingly by his quick and ready disparagement
of judges, his disdain for his fellow attorneys, and his lack of concern for and betrayal of his clients
that he is utterly unfit to practice law. The only appropriate sanction is disbarment.
JOSEPH J. NOTOPOULOS v. STATEWIDE GRIEVANCE COMMITTEE SC 17341
2006 Conn. LEXIS 30,*;277 Conn. 218;
890 A.2d 509
FACTS
"The plaintiff, an attorney, filed an application with the Probate Court for the district of West
Hartford seeking appointment as the conservator of his mother's estate and person. The court, Berman,J.,
appointed the plaintiff as conservator of his mother's estate, Denny Fuller as conservator of her person
and Carolyn Levine to investigate her care and financial assets. The plaintiff had many disagreements
with Judge Berman, including a disagreement regarding the fees of Levine and Fuller and one regarding a
do not resuscitate order issued to Fuller. On May 29, 1999, the plaintiff's mother died, and the plaintiff
and his brother were appointed coexecutors of her estate. Thereafter, the plaintiff claimed that he did not
receive timely notice of the probate decree closing his mother's [*4] estate. The plaintiff wrote a letter to
Renee Bradley, a member of the court staff, and sent copies of this letter to his brother and his mother's
physician. Notopoulous was charged in violation of Rule 8.2: "A lawyer shall not make a
statement that the lawyer knows to be false or with reckless disregard as to its truth
or falsity concerning the qualifications or integrity of a judge . ." on the basis of the
letter containing the language used by him:
1.that [Judge] Berman is now some [five and one-half] months derelict in his obligation
2.the litany of abuses of his office
3. his reprehensible extortion from the [plaintiff], without legal authority of money
4.resorting to threats to impose upon the undersigned a substantial conservator's cash
5. his reckless and irresponsible interference/ impairment of the physician-patient relationship.
6. Levine being financially motivated and medically discredited attacks on my late mother
7. (Judge Bermans)his arrogant and contemptuous issuance of a decree
8.his placement of the financial greed of his cronies above my mother's best interest
9.utter contempt for applicable requirements
10. Berman has become not merely an embarrassment to this community but a demonstrated
financial predator of its incapacitated and often dying elderly
11. seemingly impaired ability to conduct his office with the integrity and competence
ISSUES
1. WON "rule 8.2 (a) is inapplicable because the plaintiff was not acting in his professional
capacity as an attorney when he wrote the letter."

2. WON Notopoulous violated Rule 8.2 (a) of the Rules of Professional Conduct:
On appeal to the Appellate Court, the plaintiff claimed that (1) the trial court improperly concluded that
the committee, having failed to submit any evidence at the hearing, had met its burden of proving by clear
and convincing evidence that he violated rule 8.2 (a) of the Rules of Professional Conduct.
The appellate court further concluded that "there is no indication that rule 8.2 (a), either in its language or
commentary, is applicable solely to an attorney acting in his or her professional capacity.

SUPREME COURT RULING

Held. Affirmed the judgment of the Appellate Court, upholding the committee's reprimand of the
plaintiff.Affirmed the committee's finding, by clear and convincing evidence, that the plaintiff
had violated rules 8.2 (a) and 8.4 (4) of the Rules of Professional Conduct. We further agree with
the committee's argument that the Rules of Professional Conduct apply to attorneys acting in
both their personal and professional capacities. Moreover, we conclude that the plaintiff's
statements impugning the integrity of Judge Berman do not constitute speech protected by the
first amendment of the constitution of the United States.

B. RESPECT DUE TO THE COURTS AND JUDICIAL OFFICERS MUST BE MAINTAINED

VICENTE SOTTO
January 21, 1949
In re VICENTE SOTTO, for contempt of court.
FACTS:

This is a proceeding for contempt of our court against the respondent Atty. Vicente Sotto,
who was required by their Court on December 7, 1948, to show cause why he should not be
punished for contempt to court for having issued a written statement in connection with the
decision of this Court in In re Angel Parazo for contempt of court, which statement, as published
in the Manila Times and other daily newspapers of the locality, reads as follows:
As author of the Press Freedom Law (Republic Act No. 53.) interpreted by the Supreme
Court in the case of Angel Parazo, reporter of a local daily, who now has to suffer 30 days
imprisonment, for his refusal to divulge the source of a news published in his paper, I
regret to say that our High Tribunal has not only erroneously interpreted said law, but that
it is once more putting in evidence the incompetency of narrow mindedness o the
majority of its members, In the wake of so many mindedness of the majority deliberately
committed during these last years, I believe that the only remedy to put an end to so much
evil, is to change the members of the Supreme Court. To his effect, I announce that one of
the first measures, which as its objects the complete reorganization of the Supreme Court.
As it is now constituted, a constant peril to liberty and democracy. It need be said loudly,
very loudly, so that even the deaf may hear: the Supreme Court very of today is a far cry
from the impregnable bulwark of Justice of those memorable times of Cayetano Arellano,
Victorino Mapa, Manuel Araullo and other learned jurists who were the honor and glory
of the Philippine Judiciary.
In the above-quoted written statement which he caused to be published in the press, the
respondent does not merely criticize or comment on the decision of the Parazo case, which was
then and still is pending reconsideration by the Court upon petition of Angel Parazo. He not only
intends to intimidate the members of the SCt with the presentation of a bill in the next Congress,
of which he is one of the members, reorganizing the Supreme Court and reducing the members,
reorganizing the Supreme Court and reducing the members of Justices from eleven to seven, so
as to change the members of this Court which decided the Parazo case, who according to his
statement, are incompetent and narrow minded, in order to influence the final decision of said
5

case by the SC, and thus embarrass or obstruct the administration of justice. The respondent also
attacks the honesty and integrity of the Court for the apparent purpose of bringing the Justices of
into disrepute and degrading the administration of justice.
ISSUE
WON Atty. Vicente Sotto is liable for contempt of court.
RULING
Respondent Atty. Vicente Sotto was found guilty of contempt, was sentenced to pay a fine of
P1,000, with subsidiary imprisonment in case of insolvency. The respondent was also required
to show cause t why he should not be disbarred.
To hurl the false charge that this Court has been for the last years committing deliberately "so many blunders and
injustices," that is to say, that it has been deciding in favor of one party knowing that the law and justice is on the
part of the adverse party and not on the one in whose favor the decision was rendered, in many cases decided during
the last years, would tend necessarily to undermine the confidence of the people in the honesty and integrity of the
members of this Court, and consequently to lower or degrade the administration of justice by this Court. The
Supreme Court of the Philippines is, under the Constitution, the last bulwark to which the Filipino people may repair
to obtain relief for their grievances or protection of their rights when these are trampled upon, and if the people lose
their confidence in the honesty and integrity of the members of this Court and believe that they cannot expect justice
therefrom, they might be driven to take the law into their own hands, and disorder and perhaps chaos might be the
result. As a member of the bar and an officer of the courts Atty. Vicente Sotto, like any other, is in duty bound to
uphold the dignity and authority of this Court, to which he owes fidelity according to the oath he has taken as such
attorney, and not to promote distrust in the administration of justice. Respect to the courts guarantees the stability of
other institutions, which without such guaranty would be resting on a very shaky foundation.
xxxThis Court must be permitted to proceed with the disposition if its business in an orderly manner free from
outside interference obstructive of its constitutional functions. This right will be insisted upon as vital to an impartial
court, and, as a last resort, as a individual exercises the right of self-defense, it will act to preserve its existence as an
unprejudiced tribunal. . .xxx
It is also well settled that an attorney as an officer of the court is under special obligation to be respectful in his
conduct and communication to the courts, he may be removed from office or stricken from the roll of attorneys as
being guilty of flagrant misconduct.

AGUIDO LACSON, JR., ET AL

vs.
COURT OF APPEALS, HON. JOSE R. HERNANDEZ, ET AL
G.R. No. 113591 February 6, 1995
FACTS
The High court directed the counsel for the petitioners, Atty. Mario G. Fortes, to show
cause why he should not be held in contempt of court and declared liable for misconduct for his
"apparently malicious and unfounded accusation that this Court did not read the petition and for
craftily suppressing from the body of the petition the final decision in CA-G.R. CR No. 11465.

The contempt aspect of this case arose from the motion for reconsideration of Atty. Fortes
filed. He sought therein the reconsideration of the resolution which denied the instant petition.
He contends that "the petition was denied wholly on the basis of technicality"; that the "denial
did not consider the fraud sought to be stopped"; and that in peremptorily denying the petition,
this Court disregarded the purpose of judicial proceedings, i.e., "to seek the truth," even as it is
"unusual that the Resolution failed on this aspect," and upheld" the fake and falsified OCT No.
730 of the Tuazons." He further stated therein that: [i]t pained the petitioners and their counsel to
surmise that nobody cared to read the Petition. If they did they refused to understand the
arguments in order not to blur the preconceived resolution of this case.
ISSUE
WON Atty. Fortes violated Canon 11 Rule 11.03 - A lawyer shall abstain from
scandalous, offensive or menacing language or behavior before the Courts
RULING
For his violations of his oath of office, Section 20, Rule 138 of the Rules of Court, the
Code of Professional Responsibility, and the Canons of Professional Ethics, ATTY. MARIO G.
FORTES is hereby ORDERED to pay a FINE of Two Thousand Pesos(P2,000.00) and
WARNED that the commission of the same or similar acts in the future shall be dealt with more
severely.

In re: Almacen
IN THE MATTER OF PROCEEDINGS FOR DISCIPLINARY ACTION AGAINST
ATTY. VICENTE RAUL ALMACEN In L-27654, ANTONIO H. CALERO,
vs.
VIRGINIA Y. YAPTINCHAY.
G.R. No. L-27654 February 18, 1970
FACTS
This special proceeding arose from Atty. Vicente Raul Almacen's "Petition to Surrender
Lawyer's Certificate of Title," filed on September 25, 1967, in protest against what he therein
asserts is "a great injustice committed against his client by the Supreme Court." He indicts the
Court, in his own phrase, as a tribunal "peopled by men who are calloused to our pleas for
justice, who ignore without reasons their own applicable decisions and commit culpable
violations of the Constitution with impunity." His client's he continues, who was deeply
aggrieved by this Court's "unjust judgment," has become "one of the sacrificial victims before
the altar of hypocrisy." In the same breath that he alludes to the classic symbol of justice, he
ridicules the members of this Court, saying "that justice as administered by the present members
of the Supreme Court is not only blind, but also deaf and dumb." He then vows to argue the
cause of his client "in the people's forum," so that "the people may know of the silent injustice's
committed by this Court," and that "whatever mistakes, wrongs and injustices that were
committed must never be repeated." He ends his petition with a prayer that ... a resolution issue
7

ordering the Clerk of Court to receive the certificate of the undersigned attorney and counsellorat-law IN TRUST with reservation that at any time in the future and in the event we regain our
faith and confidence, we may retrieve our title to assume the practice of the noblest profession.
He reiterated and disclosed to the press the contents of the aforementioned petition. Thus, on
September 26, 1967, the Manila Times published statements attributed to him, as follows:
Vicente Raul Almacen, in an unprecedented petition, said he did it to expose the tribunal's
"unconstitutional and obnoxious" practice of arbitrarily denying petitions or appeals without any
reason.Because of the tribunal's "short-cut justice," Almacen deplored, his client was condemned
to pay P120,000, without knowing why he lost the case.
ISSUE
WON Atty. Almacen violated Rules 11.03, 11.04, 11.05 of Canon 11 of the Code of
Professional Resonsibility.
RULING
The virulence so blatantly evident in Atty. Almacen's petition, answer and oral argumentation
speaks for itself. The vicious language used and the scurrilous innuendoes they carried far
transcend the permissible bounds of legitimate criticism. They could never serve any purpose but
to gratify the spite of an irate attorney, attract public attention to himself and, more important of
all, bring ;this Court and its members into disrepute and destroy public confidence in them to the
detriment of the orderly administration of justice. Odium of this character and texture presents no
redeeming feature, and completely negates any pretense of passionate commitment to the truth. It
is not a with less than a classic example of gross misconduct, gross violation of the lawyer's oath
and gross transgression of the Canons of Legal Ethics. As such, it cannot be allowed to go
unrebuked.
Atty. Vicente Raul Almacen was suspended from the practice of law until further orders.
In resolving the case of Atty. Almacen the High Court stated:
A perusal of the more representative of these instances may afford enlightenment.
1. In Salcedo vs. Hernandez, 61 Phil. 724, where counsel branded the denial of his motion for
reconsideration as "absolutely erroneous and constituting an outrage to the rigths of the petitioner
Felipe Salcedo and a mockery of the popular will expressed at the polls," this Court, although
conceding that
It is right and plausible that an attorney, in defending the cause and rights of his
client, should do so with all the fervor and energy of which he is capable, but it is
not, and never will be so for him to exercise said right by resorting to intimidation
or proceeding without the propriety and respect which the dignity of the courts
requires. The reason for this is that respect for the courts guarantees the stability

of their institution. Without such guaranty, said institution would be resting on a

very shaky foundation,
found counsel guilty of contempt inasmuch as, in its opinion, the statements made
disclosed ... an inexcusable disrespect of the authority of the court and an
intentional contempt of its dignity, because the court is thereby charged with no
less than having proceeded in utter disregard of the laws, the rights to the parties,
and 'of the untoward consequences, or with having abused its power and mocked
and flouted the rights of Attorney Vicente J. Francisco's client ... .
2. In In re Sotto, 82 Phil. 595, counsel, a senator and the author of the Press Freedom Law,
reaching to, the imprisonment for contempt of one Angel Parazo, who, invoking said law, refused
to divulge the source of a news item carried in his paper, caused to be published in i local
newspaper a statement expressing his regret "that our High Tribunal has not only erroneously
interpreted said law, but it is once more putting in evidence the incompetency or narrow
mindedness of the majority of its members," and his belief that "In the wake of so many blunders
and injustices deliberately committed during these last years, ... the only remedy to put an end to
go much evil, is to change the members of the Supreme Court," which tribunal he denounced as
"a constant peril to liberty and democracy" and "a far cry from the impregnable bulwark of
justice of those memorable times of Cayetano Arellano, Victorino Mapa, Manuel Araullo and
other learned jurists who were the honor and glory of the Philippine Judiciary." He there also
announced that one of the first measures he would introduce in then forthcoming session of
Congress would have for its object the complete reorganization of the Supreme Court. Finding
him in contempt, despite his avowals of good faith and his invocation of the guarantee of free
speech, this Court declared:
But in the above-quoted written statement which he caused to be published in the
press, the respondent does not merely criticize or comment on the decision of the
Parazo case, which was then and still is pending consideration by this Court upon
petition of Angel Parazo. He not only intends to intimidate the members of this
Court with the presentation of a bill in the next Congress, of which he is one of
the members, reorganizing the Supreme Court and reducing the number of
Justices from eleven, so as to change the members of this Court which decided the
Parazo case, who according to his statement, are incompetent and narrow minded,
in order to influence the final decision of said case by this Court, and thus
embarrass or obstruct the administration of justice. But the respondent also attacks
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the honesty and integrity of this Court for the apparent purpose of bringing the
Justices of this Court into disrepute and degrading the administration. of justice ...
.
To hurl the false charge that this Court has been for the last years committing
deliberately so many blunders and injustices, that is to say, that it has been
deciding in favor of Que party knowing that the law and justice is on the part of
the adverse party and not on the one in whose favor the decision was rendered, in
many cases decided during the last years, would tend necessarily to undermine the
confidence of the people in the honesty and integrity of the members of this
Court, and consequently to lower ,or degrade the administration of justice by this
Court. The Supreme Court of the Philippines is, under the Constitution, the last
bulwark to which the Filipino people may repair to obtain relief for their
grievances or protection of their rights when these are trampled upon, and if the
people lose their confidence in the honesty and integrity of the members of this
Court and believe that they cannot expect justice therefrom, they might be driven
to take the law into their own hands, and disorder and perhaps chaos might be the
result. As a member of the bar and an officer of the courts, Atty. Vicente Sotto,
like any other, is in duty bound to uphold the dignity and authority of this Court,
to which he owes fidelity according to the oath he has taken as such attorney, and
not to promote distrust in the administration of justice. Respect to the courts
guarantees the stability of other institutions, which without such guaranty would
be resting on a very shaky foundation.
Significantly, too, the Court therein hastened to emphasize that
... an attorney as an officer of the court is under special obligation to be respectful
in his conduct and communication to the courts; he may be removed from office
or stricken from the roll of attorneys as being guilty of flagrant misconduct (17
L.R.A. [N.S.], 586, 594.)
3. In Rheem of the Philippines vs. Ferrer: In re Proceedings against Alfonso Ponce Enrile, et al.,
supra, where counsel charged this Court with having "repeatedly fallen" into ,the pitfall of
blindly adhering to its previous "erroneous" pronouncements, "in disregard of the law on
jurisdiction" of the Court of Industrial Relations, our condemnation of counsel's misconduct was
unequivocal. Articulating the sentiments of the Court, Mr. Justice Sanchez stressed:

10

As we look back at the language (heretofore quoted) employed in the motion for
reconsideration, implications there are which inescapably arrest attention. It
speaks of one pitfall into which this Court has repeatedly fallen whenever the
jurisdiction of the Court of Industrial Relations comes into question. That pitfall is
the tendency of this Court to rely on its own pronouncements in disregard of the
law on jurisdiction. It makes a sweeping charge that the decisions of this Court,
blindly adhere to earlier rulings without as much as making any reference to and
analysis of the pertinent statute governing the jurisdiction of the industrial court.
The plain import of all these is that this Court is so patently inept that in
determining the jurisdiction of the industrial court, it has committed error and
continuously repeated that error to the point of perpetuation. It pictures this Court
as one which refuses to hew to the line drawn by the law on jurisdictional
boundaries. Implicit in the quoted statements is that the pronouncements of this
Court on the jurisdiction of the industrial court are not entitled to respect. Those
statements detract much from the dignity of and respect due this Court. They
bring into question the capability of the members and some former members of
this Court to render justice. The second paragraph quoted yields a tone of sarcasm
which counsel labelled as "so called" the "rule against splitting of jurisdiction."
Similar thoughts and sentiments have been expressed in other cases which, in the interest of
brevity, need not now be reviewed in detail.

B. CRITICISMS OF COURTS MUST SPILL THE WALL OF DECENCY

ENRIQUE A. ZALDIVAR
vs.
THE HONORABLE SANDIGANBAYAN and HONORABLE RAUL M. GONZALEZ,
claiming to be and acting as Tanodbayan-Ombudsman under the 1987 Constitution
G.R. No. 79690-707 February 1, 1989
FACTS
Atty. Raul Gonzales was subjected to administrative proceedings after he made public
statements to the media dealing not only with matters subjudice but in a language offensive and
disrespectful to the Court and its individual members. The following is the text of the public
statements:
Tanod Scores SC for Quashing Graft Case (Phil. Daily Globe, Nov. 30, 1988)
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TANODBAYAN Justice Raul M. Gonzalez said yesterday the Supreme Court order stopping him
from investigating graft cases involving Antique Gov. Enrique Zaldivar can aggravate the
thought that affluent persons can prevent the progress of a trial."
What I am afraid of (with the issuance of the order) is that it appears that while rich and
influential persons get favorable actions from the Supreme Court, it is difficult for an ordinary
litigant to get his petition to be given due course. Gonzalez told the Daily Globe in an exclusive
interview.
Gonzalez said the high tribunal's order 'heightens the people's apprehension over the justice
system in this country, especially because the people have been thinking that only the small fly
can get it while big fishes go scot-free."
Gonzalez was reacting to an order issued by the tribunal last week after Zaldivar petitioned the
court to stop the Tanodbayan from investigating graft cases filed against him.
Zaldivar had charged that Gonzalez was biased in his investigations because the latter wanted to
help promote the political fortunes of a friend from Antique, lawyer Bonifacio Alentajan.
Acting on Zaldivar's petition, the high court stopped Gonzalez from investigating a graft charge
against the governor, and from instituting any complaint with the Sandiganbayan.
While President Aquino had been prodding me to prosecute graft cases even if they involve the
high and mighty, the Supreme Court had been restraining me. While I don't wish to discuss the
merits of the Zaldivar petition before the Supreme Court, I am a little bit disturbed that (the
order) can aggravate the thinking of some people that affluent persons can prevent the progress
of a trial, he said. Phil. Daily Globe, Nov. 30, 1988.
ISSUE
WON

the argument of Atty. Raul M. Gonzales that he was merely exercising his

constitutional right of free speech and qualified privileged communication is tenable.

RULING

It appearing that respondent Raul M. Gonzalez has made public statements to the media which
not only deal with matters subjudice in the issues of the "Daily Inquirer," the "Journal, the
"Manila Times," the "Philippine Star," the "Manila Chronicle" the "Daily Globe" and the "Manila
Standard" of April 29 and 30, and May 1, 1988, but also appear offensive to and disrespectful of
the Court and its individual members and calculated, directly or indirectly, to bring the Court into
disrepute, discredit and ridicule and to denigrate and degrade the administration of justice,

GONZALES WAS SUSPENDED INDEFINITELY

12

The principal defense of respondent Gonzalez is that he was merely exercising his constitutional
right of free speech. He also invokes the related doctrines of qualified privileged
communications and fair criticism in the public interest.
Respondent Gonzalez is entitled to the constitutional guarantee of free speech. No one seeks to
deny him that right, least of all this Court. What respondent seems unaware of is that freedom of
speech and of expression, like all constitutional freedoms, is not absolute and that freedom of
expression needs on occasion to be adjusted to and accommodated with the requirements of
equally important public interests. One of these fundamental public interests is the maintenance
of the integrity and orderly functioning of the administration of justice. There is no antinomy
between free expression and the integrity of the system of administering justice. For the
protection and maintenance of freedom of expression itself can be secured only within the
context of a functioning and orderly system of dispensing justice, within the context, in other
words, of viable independent institutions for delivery of justice which are accepted by the
general community.
Only slightly (if at all) less important is the public interest in the capacity of the Court effectively
to prevent and control professional misconduct on the part of lawyers who are, first and
foremost, indispensable participants in the task of rendering justice to every man. Some courts
have held, persuasively it appears to us, that a lawyer's right of free expression may have to be
more limited than that of a layman. 52
It is well to recall that respondent Gonzalez, apart from being a lawyer and an officer of the
court, is also a Special Prosecutor who owes duties of fidelity and respect to the Republic and to
this Court as the embodiment and the repository of the judicial power in the government of the
Republic. The responsibility of the respondent "to uphold the dignity and authority of this Court'
and "not to promote distrust in the administration of justice 53 is heavier than that of a private
practicing lawyer.
Respondent Gonzalez claims to be and he is, of course, entitled to criticize the rulings of this
Court, to point out where he feels the Court may have lapsed into error. Once more, however, the
right of criticism is not unlimited. Its limits were marked out by Mr. Justice Castro in In re
Almacen which are worth noting
But it is the cardinal condition of all such criticism that it shall be bonafide and
shall not spill over the walls of decency and propriety. A wide chasm exists
between fair criticism, on the one hand, and abuse and slander of courts and the
judges thereof, on the other. Intemperate and unfair criticism is a gross violation
of the duty of respect to courts. It is such a misconduct that subjects a lawyer to
disciplinary action.
The lawyer's duty to render respectful subordination to the courts is essential to
the orderly administration of justice. Hence, in the assertion of their clients' rights,
lawyers even those gifted with superior intellect are enjoined to rein up their
tempers.

13

The instant proceeding is not addressed to the fact that respondent has criticized the Court; it is
addressed rather to the nature of that criticism or comment and the manner in which it was
carried out.

C. PLEADINGS WITH DEROGATORY, OFFENSIVE OR MALICIOUS STATEMENTS

SUBMITTED TO THE COURT OR JUDGE IN WHICH PROCEEDINGS ARE PENDING
CONSTITUTE DIRECT CONTEMPT
KELLY R. WICKER and ATTY. ORLANDO A. RAYOS, Petitioners,
vs. HON. PAUL T. ARCANGEL, as Presiding Judge
G.R. No. 112869. January 29, 1996
FACTS

Kelly Wicker, with his wife Wynee Dieppe and the Tectonics Asia Architects and Engineering
Co., brought suit in the Regional Trial Court of Makati against the LFS Enterprises, Inc. and
others, for the annulment of certain deeds by which a house and lot at Forbes Park, which the
plaintiffs claimed they had purchased, was allegedly fraudulently titled in the name of the
defendant LFS Enterprises and later sold by the latter to codefendant Jose Poe. The case,
docketed as Civil Case No. 14048, was assigned to Branch 134 formerly presided over by Judge
Ignacio Capulong who later was replaced by respondent Judge Paul T. Arcangel.
It appears that Wickers counsel, Atty. Orlando A. Rayos, filed a motion seeking the inhibition of
respondent judge from the consideration of the case. In their pleadings the following were
alleged: Plaintiffs have information that the Acting Presiding Judge was personally recruited
from the south by Atty. Benjamin Santos and/or his wife, Atty. Ofelia Calcetas-Santos, one time
member of the Judicial and Bar Council, against whom plaintiff Kelly R. Wicker filed
Administrative Case No. 3796, and although said case was dismissed, nevertheless, plaintiffs feel
that it was the reason for Atty. Ofelia Calcetas-Santos relief; Plaintiffs have reason to doubt the
partiality and integrity of His Honor and to give a fighting chance for plaintiffs to prove their
case, since this will be the last case to recover the partnership property, plaintiffs feel that His
Honor inhibit himself and set this case for re-raffle. Respondent judge found offense in the
allegations on the motion for inhibition filed by complainants, and in an order, held them guilty
of direct contempt and sentenced each to suffer imprisonment for five (5) days and to pay a fine
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of P100.00. Petitioners filed a motion for reconsideration, which respondent judge denied for
lack of merit in his order of Dec 17, 1993.
ISSUE
WON Atty. Rayos submitted pleadings that are offensive, derogatory or malicious in
violation of Canon 11 of the Code of Professional Responsibility constituting direct contempt.
RULING
HELD. The High Court affirmed Judge Arcangles findings that petitioners are guilty of
contempt.
The power to punish for contempt is to be exercised on the preservative and not on the
vindictive principle. Only occasionally should it be invoked to preserve that respect without
which the administration of justice will fail.
D. LAWYERS LANGUAGE MUST BE DIGNIFIED
In Re Quirico del Mar, For Disciplinary action as member of the Philippine Bar,
JORGE MONTECILLO and ATTY. QUIRICO DEL MAR,
vs.
FRANCISCO M. GICA, MAGNO S. GATMAITAN, JOSE N. LEUTERIO, and RAMON
G. GAVIOLA, Justices of the Court of Appeals, respondents.
G.R. No. L-36800 October 21, 1974
FACTS
Petitioner Atty. Quirico del Mar of Cebu City in G. R. No. L-36800, and as respondent in
contempt proceedings both in the Court of Appeals and in this Court, virtually focused the
limelight on himself and relegated to insignificance and relegated to insignificance the principal
issue raised in the petition for certiorari to review the entitled "Francisco M. Gica vs. Hon.
Santiago O. Taada, et al" which was denied due course by this Court's resolution dated May 14,
1973, for lack of merit.
When the SC affirmed the Trial Courts decision, Atty. Del Mar alleged SC acted with
intent and malice, if not with gross ignorance of the law, in disposing of the case of his client; he
wrote threatening letters to CA/SC;

filed civil/damages case in CFI Cebu and criminal case

for falsification of public document; filed case under RPC 204/205, with the Office of the
President against CA justices, and threatened SC to file the same for knowingly rendering unjust
judgment, or doing it through ignorance. Earlier when suspended by the Court of Appeals he
offered to retire as lawyer. Here is the content of the letter: I would have filed against the Justices
supporting the same, civil and criminal suit as I did to the Justices of the Court of Appeals who,
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rewarding the abhorent falsification committed by Mr. Gica, reversed for him the decisions of the City
Court and the Court of First Instance of Cebu, not with a view to obtaining a favorable judgment therein
but for the purpose of exposing to the people the corroding evils extant in our Government , so that they
may well know them and work for their extermination"

ISSUE
WON Atty. Del Mar is guilty of direct contempt of Court
RULING
HELD. For his misconduct towards the Supreme Court, he was suspended indefinitely
from the practice of law until further orders of the Court.
The documented incidents as narrated in the Appellate Court's Resolution of March 5, 1973,
cannot more eloquently depict the very manifest and repeated threats of respondent del Mar to bludgeon
the Justices of the Fourth Davison into reconsidering its decision which happened to be adverse to
respondent's client. Respondent del Mar, instead of presenting lucid and forceful arguments on the merits
of his plea for a reconsideration to convince the Justices of the Fourth Division of the alleged error in
their decision, resorted to innuendos and veiled threats, even casting downright aspersion on the Justices
concerned by insinuating that for their decision they could be criminally and civilly liable for knowingly
rendering unjust judgment, or doing it through ignorance.
It is manifest that respondent del Mar has scant respect for the two highest Courts of the land
when on the flimsy ground of alleged error in deciding a case, he proceeded to challenge the integrity of
both Courts by claiming that they knowingly rendered unjust judgment. In short, his allegation is that they
acted with intent and malice, if not with gross ignorance of the law, in disposing of the case of his client.
We note with wonder and amazement the brazen effrontery of respondent in assuming that his personal
knowledge of the law and his concept of justice are superior to that of both the Supreme Court and the
Court of Appeals. His pretense cannot but tend to erode the people's faith in the integrity of the courts of
justice and in the administration of justice. He repeatedly invoked his supposed quest for law and justice
as justification for his contemptuous statements without realizing that, in seeking both abstract elusive
terms, he is merely pursuing his own personal concept of law and justice. He seems not to comprehend
that what to him may be lawful or just may not be so in the minds of others. He could not accept that what
to him may appear to be right or correct may be wrong or erroneous from the viewpoint of another. We
understand that respondent's mind delves into the absolute without considering the universal law of
change. It is with deep concern that We view such a state of mind of a practicing lawyer since what We
expect as a paramount qualification for those in the practice of law is broadmindedness and tolerance,
coupled with keen perception and a sound sense of proportion in evaluating events and circumstances.
For a lawyer in the twilight of his life, with supposed physical and mental ailments at that, who dares to
challenge the integrity and honor of both the Supreme Court and Court of Appeals, We have nothing but
commiseration and sympathy for his choosing to close the book of his long years of law practice not by
voluntary retirement with honor but in disciplinary action with ignominy and dishonor. To those who are
in the practice of law and those who in the future will choose to enter this profession, We wish to point to
this case as a reminder for them to imprint in their hearts and minds that an attorney owes it to himself to
respect the courts of justice and its officers as a fealty for the stability of our democratic institutions.
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SANGALANG VS IAC
G.R. No. 71169 August 30, 1989
FACTS
Counsel for BEL AIR VILLAGE ASSOCIATION Atty. J. Cezar Sangco, in His MOR on
the SC decision favoring Ayala Corp. and adversely affecting BAVA-Bel Air Village Ass. when
SC allowed the opening of Jupiter St. to the public submitted his pleading consisting among
others of the following :

The decision of this Court in the above-entitled case reads more like a Brief for Ayala ...

[t]he Court not only put to serious question its own integrity and competence but also
jeopardized its own campaign against graft and corruption undeniably pervading the
judiciary ...

the blatant disregard of controlling, documented and admitted facts not put in issue xxx
the extraordinary efforts exerted to justify such arbitrariness and the very strained and
unwarranted conclusions drawn therefrom, are unparalleled in the history of this Court ...

a manifestation of this Court's unusual partiality to Ayala and puts to serious question its
integrity on that account.

unusual exercise of such arbitrariness

ISSUE
WON the language of Atty. Sangco in his pleading consist of derogatory, offensive or
malicious language in violation of Rule11.03
RULING
Held. Atty. Sangco was found guilty of contempt, for resorting to insulting language
amounting to disrespect towards the Court within the meaning of Section 1, of Rule 71, of the
Rules of Court. Clearly, however, his act also constitutes professional misconduct and
malpractice as the term is defined by Canon 11 of the Code of Professional Responsibility.
Aside from contempt, Atty. Sangco faces punishment for professional misconduct or malpractice.

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WHEREFORE Atty. J. Cezar Sangco is (1) SUSPENDED from the practice of law for three (3) months
effective from receipt hereof, and (2) ORDERED to pay a fine of P 500.00.
The court find Atty. Sangcos remarks in his motion for reconsideration, disparaging, intemperate, and
uncalled for. His suggestions that the Court might have been guilty of graft and corruption in acting on
these cases are not only unbecoming, but comes, as well, as an open assault upon the Court's honor and
integrity. In rendering its judgment, the Court yielded to the records before it, and to the records alone,
and not to outside influences, much less, the influence of any of the parties. Atty. Sangco, as a former
judge of an inferior court, should know better that in any litigation, one party prevails, but his success will
not justify indictments of bribery by the other party. He should be aware that because of his accusations,
he has done an enormous disservice to the integrity of the highest tribunal and to the stability of the
administration of justice in general.
Atty. Sangco is entitled to jis opinion but not to a license to insult the court with derogatory statements
and recourses. xxx
He himself admits that "[a]s a judge I have learned to live with and accept with grace criticisms of my
decisions". 13 Apparently, he does not practice what he preaches. Of course, the Court is not unreceptive to
comment and critique of its decisions, but provided they are fair and dignified. Atty. Sangco has
transcended the limits of fair comment for which he deserves this Court's rebuke.

PARAGAS V. CRUZ,
14 SCRA 809

FACTS
Atty. Jeremias T. Sebastian , de parte counsel for Paragas, in his written motion for
Reconsideration of the Trial Ccourt judgment, stated: xxxBut when the laws and the rules are
violated, the victims resort, sometimes, to armed force and to the ways of the cave-men! We do
not want Verzosa and Reyes repeated again and again, killed in the premises of the Supreme
Court and in those of the City Hall of Manila. Educated people should keep their temper under
control at all times! But justice should be done to all concerned to perpetuate the very life of
Democracy on the face of the earth."
ISSUE
WON the language of the motion for reconsideration filed by Atty. Sebastian is
contemptuous in violation of Rule 11.03 odf the Code of Professional Responsibility.
RULING
Held. The expressions contained in the motion for reconsideration, are plainly contemptuous and
disrespectful, and reference to the recent killing of two employees is but a covert threat upon the
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members of the Court. Atty. Jeremias T. Sebastian was found guilty of direct contempt, and
sentenced to pay a fine of P200.00 within ten days from notice thereof, or, in case of default, to
suffer imprisonment not exceeding ten (10) days.

E. CRITICISM MADE IN GOOD FAITH MAYBE TOLERATED

ERNESTO B. FRANCISCO, JR., PETITIONER, VS. UEM-MARA PHILIPPINES
CORPORATION, TOLL REGULATORY BOARD AND PUBLIC ESTATES
AUTHORITY, RESPONDENTS
G.R. Nos. 135688-89, October 18, 2007
FACTS
Petitioner submitted a motion to cite Attys. Napoleon J. Poblador and Manuel Joseph R.
Bretaa III in contempt of court for showing disrespect and resorting to offensive language
against RTC Judge Guadiz, Jr. when they stated:
Despite the obvious legality of the project, petitioner, either by sheer arrogance or a malicious
refusal to acknowledge the truth that the [MCTEP] and the imposition of toll fees for the use of
the Coastal Road are legal and above board initiated what is no more than a nuisance suit and
secured from an insufficiently-informed judge an illegal writ of preliminary injunction which
public respondent, the Honorable [CA], subsequently reversed.
ISSUE
WON the phrase insufficiently-informed is offensive language.
RULING

HELD. insufficiently informed IS not intemperate language

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The criticism was done in good faith. While the Court recognizes a litigant's right
to criticize judges and justices in the performance of their functions, it is the
cardinal condition of all such criticism that it shall be bona fide and shall not spill
over the walls of decency and propriety. A wide chasm exists between fair
criticism, on the one hand, and abuse and slander of courts and the judges (or
justices) thereof, on the other. Intemperate and unfair criticism is a gross violation
of the duty of respect to courts.
We cannot say that the use of the adjective insufficiently-informed is disrespectful,
abusive or slanderous. Besides,[it] is well settled that the power to punish a person in
contempt of court is inherent in all courts to preserve order injudicial proceedings and to
uphold the due administration of justice. Judges however are enjoined to exercise such
power judiciously and sparingly, with utmost restraint, and with the end in view of
utilizing the same for correction and preservation of the dignity of the court, and not for
retaliation or vindictiveness.
F. A LAWYER SHALL NOT ATTRIBUTE TO A JUDGE MOTIVE NOT SUPPORTED BY
THE RECORD OR HAVE NO MATERIALITY TO THE CASE.
ROXAS V ZUZUARREGI
G.R. NO. 152072. JULY 12, 2007
FACTS
In a Resolution dated 26 September 2006, the Court En Banc [the full court] ordered
Atty. Romeo G. Roxas to explain in writing why he should not be held in contempt of court and
subjected to disciplinary action when he, in a letter dated 13 September 2006 addressed to
Associate Justice Minita V. Chico-Nazario with copies thereof furnished the Chief Justice and all
the other Associate Justices, intimated that Justice Nazario decided G.R. No. 152072 and No.
152104 on consideration other than the pure merits of the case and called the Supreme Court a
"dispenser of injustice. The letter reads: " As an officer of the court, I am shocked beyond my
senses to realize that such a wrongful and unjust decision has been rendered with you no less as
the ponente. This terrible decision will go down in the annals of jurisprudence as an egregious
example of how the Supreme Court, supposedly the last vanguard and bulwark of justice is itself
made, wittingly or unwittingly, as a party to the wrongdoing by giving official and judicial
sanction and conformity to the unjust claim of the Zuzuarreguis. We cannot fathom how such a
decision could have been arrived at except through consideration other than the pure merits of
the case. x x x
We cry out in disbelief that such an impossible decision could spring forth from the Supreme
Court, the ultimate administrator and last bulwark of justice. As it stand, instead of being
administrator of justice, the Supreme Court is ironically a dispenser of injustice. x x x
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As for your Honor, sleep well if you still can.

The decision referred to in the letter is the Court's decision in these consolidated cases where
Attys. Roxas and Santiago N. Pastor were ordered to return, among others, to Antonio de
Zuzuarregui, Jr. et al. the amount of PhP 17,073,224.84; the amount representing the interests on
the money of their client; such amount having been appropriated by the counsel and Pastor for
themselves and to which their clients are entitled.
ISSUE
WON Atty. Roxas is guilty of indirect contempt.
RULING
Held. The High Court found the statements made by Atty. Roxas to have been made mala
fides and exceeded the boundaries of decency and propriety. By his unfair and unfounded
accusation against Justice Nazario, and his mocking of the Court for allegedly being part of a
wrongdoing and being a dispenser of injustice, he abused his liberty of speech.
Under the circumstances, we find Atty. Romeo G. Roxas guilty of indirect contempt of court
under Section 3, Rule 71 of the 1997 Rules of Civil Procedure, as amended.
Atty. Romeo G. Roxas was found GUILTY of indirect contempt of court. FINED P30,000.00
to be paid within ten (10) days from receipt of this Resolution and WARNED that a repetition of
a similar act will warrant a more severe penalty.
When confronted with actions and statements, from lawyers and non-lawyers alike, that
tend to promote distrust and undermine public confidence in the judiciary, this Court will
not hesitate to wield its inherent power to cite any person in contempt. In so doing, it
preserves its honor and dignity and safeguards the morals and ethics of the legal
profession

A.M. No. 05-3-04-SC. July 22, 2005

RE: LETTER DATED 21 FEBRUARY 2005 OF ATTY. NOEL S. SORREDA.
FACTS

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In a letter, Atty. Sorreda recounted the alleged circumstances surrounding the dismissal on
February 7, 2000 of the very first case he filed with the Court, UDK-12854, entitled Ramon
Sollegue vs. Court of Appeals, et al. Frustrated with the adverse ruling thereon, Atty. Sorreda
had previously written a letter dated April 2, 2001 addressed to the Chief Justice, copy furnished
all the Associate Justices of this Court, the Court of Appeals and the Office of the Solicitor
General, denouncing the Court, as follows:
Mr. Chief Justice, I believe the manner the Court comported itself in the aforesaid case is totally
execrable and atrocious, entirely unworthy of the majesty and office of the highest tribunal of the
land. It is the action not of men of reason or those who believe in the rule of law, but rather of
bullies and tyrants from whom 'might is right.
I say, shame on the High Court, for shoving down a hapless suitor's throat a ruling which, from
all appearances, it could not justify.
ISSUE
WON Atty. Sorreda violated Rule 11, 11.03 &11.04 of the Code of Professional
Responsibility.
RULING:
ATTY. NOEL S. SORREDA is found guilty both of contempt of court and violation of
the Code of Professional Responsibility amounting to gross misconduct as an officer of the court
and member of the Bar. He is hereby indefinitely SUSPENDED as a member of the Bar and is
prohibited from engaging in the practice of law until otherwise ordered by this Court.
Unfounded accusations or allegations or words tending to embarrass the court or to bring it into
disrepute have no place in a pleading. Their employment serves no useful purpose. On the
contrary, they constitute direct contempt of court or contempt in facie curiae and a violation of
the lawyers oath and a transgression of the Code of Professional Responsibility.
Atty Sorredas conduct likewise violated the Code of Professional Responsibility, specifically 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.
xxx
Rule 11.03 A lawyer shall abstain from scandalous, offensive or menacing language or
behavior before the courts.

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Rule 11.04 A lawyer shall not attribute to a judge motives not supported by the record or
having no materiality to the case.

G. LAWYER CAN DEMAND THAT THE MISBEHAVIOR OF A JUDGE BE PLACED ON

RECORD; ACT NOT CONTEMPTUOUS
IN RE: AGUAS, 1PHIL.1
FACTS
On the 29th of August, 1900, during the progress of a trial then being held before the Court of
First Instance at Bacolor, in the Province of Pampanga, the court had occasion to caution Angel
Alberto, a witness in the case, not to look at the attorney for the defendant but to fix his attention
on the judge who was at the time examining him. It seems that the witness did not give heed to
this warning, and the judge thereupon arose from his seat and approaching the witness, seized
him by the shoulders, and using the expression, "Lingon ang mucha" ("Look at me"), either
shook him, as insisted by the attorney for the defendant, or only turned him about, as claimed by
the judge and others. Whether the witness was shaken or only turned about, at all events "seizing
him," brought the defendant's attorney to his feet, who, protesting against the action of the judge
as coercive of the witness, demanded that a record be made of the occurrence and that the further
hearing of the case be postponed. Two days afterward the clerk entered in his record as recital of
the incident substantially as above, and also a statement that on other and prior occasions the
attorney, Marcelino Aguas, had been wanting in respect to the court by making use of "improper
phrases," and by interrupting opposing counsel in their examination of witnesses. The court on
this record adjudged the attorney to be in contempt of court and suspended him from the practice
of his profession for a period of twenty days. The attorney appealed, but his appeal having been
disallowed by the lower court, he asked to be heard in justification, which was granted.
ISSUE
WON Atty. Aguas was guilty of contempt of court for demanding that a record be made
of the misbehaviour of the judge.

RULING

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Both testimony and finding state a mere conclusion which, in the absence of the facts
from which it was deduced, is wholly valueless to support a judgment of contempt. The
judgment appealed from was reversed.
CONCLUSION
On the basis of the foregoing

pieces of landmark jurisprudence on

legal ethics rendered by the

Philippine Supreme Court vis--vis the US Supreme Court, we are led to the conclusion that we have yet
to see the maturity of our legal system tilted towards the sacredness of the freedom of speech and
expression. As the foregoing cases revealed, most of the decisions were based on violations of the Code
of Professional Responsibility and were not all centered on protected speech. We would like to believe
that the maturity of the American legal system after all, may not be solely the reason for their progressive
countenance along the freedom of expression issue. Cultural differences so it seems may be the
rationale behind. For one thing culture is one factor that differentiates races from one another. In the
same manner that the enjoyment and abuse of democratic processes in the Philippine setting is very much
wanting as yet in comparison to the American brand ofdemocracy, lawyers will have to content
themselves with the tilting of decisions of the courts on the rules of ethics rather than on protection of
speech. The cases of derogatory, offensive, malicious, vituperative and intemperate language we saw
taken by the attorneys involved in the aforediscussed cases may not be appalling to the typical American
but certainly, reasonable and well-meaning law practitioners and those with unimpeacheable characters
would

agree that after all,

the legal canons and the Philippine Lawyers Rules of Professional

Responsibility were not established in vain. There must be set standards to prevent outbursts of emotions
arising from the strains of legal proceedings. While there are undertones questioning the fact that the
Supreme Court is made up only of fifteen (15) legally competent persons and hence there couldnt be
any assurance that all those 15 are always right or of unimpeachable integrity after all, what matters
most is the inherent goodness of man. Erroneous judicial decisions , we are very sure, do happen but
we believe the decisions by the lower courts and thereafter by the Supreme Court are on the over-all, in
line with the basic tenets of Judicial and Legal Ethics. And with the Supreme Court being the last
recourse of justice among the three branches of government, we have to have that resolve that the courts
must be always given high regard, the judges must be accorded the highest respects and the other
judicial workers accordingly respectedto ensure that the citizenry may not lose faith in our legal
system.
First and foremost to comply with,

and called upon to faithfully abide with the fundamental

norms of legal ethics, is no other than the lawyer, on whose shoulder is entrusted the nobility of his
tripartite obligation to his client, to the public and to the courts.

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By: Iluminada J. Adriano and Flor Marie Joy Reyes

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