Regala vs.

Sandiganbayan
PCGG want to build up their case against Eduardo Coujuanco
for the anomalies in the COCO LEVY FUNDS. PCGG wants
petitioners divulge that Cojuangco indeed was a client of their
firm, as well as other information regarding Cojuangco.
Issue: Can the PCGG compel petitioners to divulge its clients
name?

identity is privileged.
3) Where the governments lawyers have no case against an
attorneys client unless, by revealing the clients name, the said
name would furnish the only link that would form the chain of
testimony necessary to convict an individual of a crime, the
clients name is privileged.
That client identity is privileged in those instances where a
strong probability exists that the disclosure of the client's
identity would implicate the client in the very criminal activity
for which the lawyers legal advice was obtained.

Held: NO.
As a matter of public policy, a clients identity should not be
shrouded in mystery. The general is that a lawyer may not
invoke the privilege and refuse to divulge the name or identity
of his client.
1) the court has a right to know that the client whose privileged
information is sought to be protected is flesh and blood.
2) the privilege begins to exist only after the attorney-client
relationship has been established. The attorney-client privilege
does not attach until there is a client.
3) the privilege generally pertains to the subject matter of the
relationship.
Finally, due process considerations require that the opposing
party should, as a general rule, know his adversary. A party
suing or sued is entitled to know who his opponent is. He
cannot be obliged to grope in the dark against unknown forces.
Except:
1) Client identity is privileged where a strong probability exists
that revealing the clients name would implicate that client in
the very activity for which he sought the lawyers advice.
2) Where disclosure would open the client to civil liability, his

Spouses Sangalang vs. IAC and Ayala Corporation, [G.R. No.

71169. August 30, 1989.]
Facts: The incident before the Court refers to charges for contempt
against Atty. J. CezarSangco, counsel for the petitioners Spouses
Jose and LutgardaSangalang.
On February 2, 1989, the Court issued a Resolution, requiring,
among other things, Atty. Sangco to show cause why he should not
be punished for contempt "for using intemperate and accusatory
language." On March 2, 1989, Atty. Sangco filed an explanation.
The Court finds Atty. Sangco's remarks in his motion for
reconsideration, particularly, . . . The 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 . . . 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.
Issue: Whether or not the counsels act constitutes malpractice in
violation of the Codes (CPR) provision on the use of scandalous
offensive or menacing language or behavior before the courts.

Held: In rendering its judgment, the Court yielded to the records

The Court in their "show-cause" Resolution, they sought to hold Atty.

before it, and to the records alone, and not to outside influences,

Sangco in contempt, specifically, for resort to insulting language

much less, the influence of any of the parties. Atty. Sangco, as a

amounting to disrespect toward the Court within the meaning of

former judge of an inferior court, should know better that in any

Section 1, of Rule 71, of the Rules of Court. Clearly, however, his act

litigation, one party prevails, but his success will not justify

also constitutes malpractice as the term is defined by Canon 11 of

indictments of bribery by the other party. He should be aware that

the Code of Professional Responsibility.

because of his accusations, he has done an enormous disservice to

CAYETANO VS. MONSOD

the integrity of the highest tribunal and to the stability of the

DISSENT:

administration of justice in general. Atty. Sangco is entitled to his

Most of the dissents focused on the issue that the

Constitution requirement pertains to habitual practice of law.
The dissenters pointed out that for the past ten years,
Monsod really seldom practiced law. This group believed
that the Constitution required that the practice of law be on
a regular basis. Justice Padilla even came up with
qualifications habituality; compensation; application of law,
legal principle, practice or procedure; and atty.-client
relationship to determine w/n a person has been engaged
in the practice of law..

opinion, but not to a license to insult the Court with derogatory

statements and recourses to argumenta ad hominem . In that event,
it is the Court's duty "to act to preserve the honor and dignity . . . and
to safeguard the morals and ethics of the legal profession."