Samar Mining Company vs Francisco Arnado

24 SCRA 402 – Legal Ethics – Duty to Assist in the Administration of Justice

In 1958, Rufino Abuyen won a labor case against Samar Mining Company. Abuyen was awarded
compensation plus hospitalization expenses for a disease he incurred while working for Samar
Mining. The decision was rendered by Pompeyo Tan, a labor lawyer duly appointed by Francisco
Arnado, a regional administrator of the Department of Labor. In 1961, Samar Mining’s lawyer,
Atty. Benedicto Arcinas, filed an action for certiorari before CFI Cebu contending that Tan has no
authority or jurisdiction over said case because he was a “mere labor lawyer” who had no
authority to render the award being complained of. CFI Cebu dismissed the petition of Arcinas.

Meanwhile, in the same year, the Supreme Court made a ruling in the case of Caltex v. Villanueva
(L-15658, August 21, 1961) that duly appointed hearing officers by regional administrators of the
labor department may issue awards. Notwithstanding this ruling, Arcinas still filed an appeal
before the Supreme Court.

ISSUE: Whether or not the appeal has merit.

HELD: No. It is obvious that the purpose of the filing is just to delay and prolong the litigation in
the hope of “draining the resources of the poorer party” “and of compelling it to submit out of
sheer exhaustion.” The conduct of Atty. Arcinas is hardly compatible with the duty of the Bar to
assist in the Administration of Justice, not to obstruct or defeat the same. The Supreme Court
ordered Samar Mining and Atty. Arcinas to shoulder the litigation costs of this case jointly and
severally.