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REPUBLIC OF THE PHILIPPINES

Office of the Bar Confidant


SUPREME COURT – En Banc – MANILA

Karl Mico Alangui,


Name of others if there are any
Name of others if there are any
Name of others if there are any

Complainant,

-versus- A.C. NO.______________


For: Disbarment
Atty. Lorenzo Gadon,
Respondent.
X-------------------------------X

VERIFIED DISBARMENT COMPLAINT / LETTER-AFFIDAVIT


(For violating the following: (1)Rule 138 Section 20 (f) of the Rules
of court, (2) Canon 7.03 of the, (3) Canon 8.01
Code of Professional Responsibility and the (4) Lawyers Oath)

PREFATORY SATEMENT
As vanguards of the law, we from the different Law Universities and
Colleges throughout Baguio and Benguet, from the moment we stepped
inside law school, have embraced the herculean responsibility and
duty to defend the very profession we sought so hard to learn by
warding it from any attacks to stain its noble spirit.
We believe that learning without practicing is an abomination within
a community of learners, thus we submit this complaint.

Chief Justice Maria Lourdes Sereno,


and the MEMBERS, En Banc, SUPREME COURT,
Padre Faura, Manila (IBP or SC?)

Your Honors,
We, law students, of legal age, coming from the different
Universities and College of Baguio and Benguet, residing in Baguio
and LaTrinidad, Benguet, in our private capacity, after duly sworn in
accordance to law hereby depose and state:

1. Karl Mico Alangui is of legal age, Single, Filipino


Citizen, a resident of Baguio, and a law student of Saint Louis
University
2. Jerry Gittabao is of legal age, Married, Filipino
Citizen, a resident of Baguio, and a law student of University of
Baguio
3. Maureen Bandao is of Legal age, Single, Filipino
Citizen, a resident of Baguio, and a law student of University of
Baguio
4. Name of others if there are any
5. Name of others if there are any
6. Name of others if there are any
7. Name of others if there are any
8. Respondent is a member of the Bar.

9. We are filling an administrative complaint against


herein respondent, Atty Lorenzo Gadon for violation of oath as a
lawyer and the Code of Professional Responsibility when he displayed
his arrogance and his unbecoming as a lawyer before dissenters,
composed of lawyers along with law students and non-government multi-
sectoral and civic organizations, during the oral arguments of Chief
Justice Maria Lourdes Sereno at the Supreme Court compound during
Supreme Court summer sessions in Baguio City.

10. On April 10, 2018, non-government multi-sectoral and


civic organizations along with students of law and legal luminaries
of Baguio staged a peaceful street demonstration outside the gates of
the Supreme Court observing their vested right of dissent in
registering their support to Chief Justice Maria Lourdes Sereno.

11. While dissenters peacefully go with their peaceful


program, Atty Lorenzo Gadon, out in the open and before the peaceful
dissenters, willfully and grossly demonstrated an immoral act that is
beyond the realms of the lawyer profession.

12. Atty Lorenzo Gadon waved his middle finger in the air
directing it to the peaceful street demonstration while shouting,
mga bobo! Putang-ina mo!, countless times to the peaceful dissenters.
(emphasis supplied)

13. Dissenters present that time were composed of multi-


sectoral non-government and civic organization along with law
students and lawyers. (emphasis supplied)

14. The willful and grossly immoral act displayed by Atty


Lozeno Gadon was also witnessed by the media who were there, as part
of their job, to cover the peaceful demonstration of dissenters.
(emphasis supplied)

15. Unfazed even with presence of the media, Atty Lorenzo


Gadon, with sheer arrogance, continued with his slurs and waving of
his middle finger even when the cameras and microphones are directed
at him. (emphasis supplied)
16. Atty Lorenzo Gadon’s willful and grossly immoral act
extended even after the incident in Baguio, he was quoted in an
interview with ANC saying;

“I was thinking of actually filing a petition to the


Supreme Court to disbar me. If this bar thing is the only
thing that will constrain me from getting back at them,
then I’d rather lose my license. I cannot allow myself to
be insulted,”. A copy of the article is hereto attached as
Annex 1

17. Also, despite the looming threats of disbarment


against him coming the watchful eyes of the legal community, he was
again caught saying;
“I don’t care if I’m disbarred. I will still eat delicious
food and live comfortably. I don’t depend on income from
lawyering alone unlike some IBP officials.” He likewise
threatened the IBP stating, “I will also file disbarment
case any IBP officials for supporting Sereno. Because
their acts and support are considered as abetting the
illegal acts of Sereno, they are upholding the violation
of the constitution by Sereno therefore they are also
liable for violating the code of ethics” (emphasis
supplied)

18. Based on the foregoing facts, it very clear that


herein respondent ‘willfully and grossly violated the following;
2. Rule 138 of the Rules of Court, particularly on
Section 20 (f) on Duties of an Attorney, stating, “to
abstain from all offensive personality…” (emphasis
supplied)
3. Canon 7, stating: A lawyer shall all times uphold the
integrity and dignity of the legal profession and
support the activities of the IBP. Likewise, on
paragraph (3) of the same Canon stating, A lawyer
shall not engage in conduct that adversely reflects on
his fitness to practice law, nor shall he whether in
public or private life, behave in a scandalous manner
to the discredit of the legal profession. (emphasis
supplied)
4. Canon 8, stating: A lawyer shall conduct himself with
courtesy, fairness and candor towards his professional
colleagues, and shall avoid harassing tactics against
opposing counsel. Likewise, on paragraph (1) of the
same Canon stating, a lawyer shall not, in his
professional dealings, use language which is abusive,
offensive or otherwise improper. (emphasis supplied)
On violation against Rule 138 of the Rules of Court, particularly on
Section 20 (f) Duties of an Attorney

15.Atty Lorenzo Gadon waving his middle finger while


shouting discriminatory slurs is an obvious
manifestation that he did not ‘abstain from all
offensive party’, but rather went on the contrary
against the peaceful dissenters along with law students
and lawyers registering their valid support to Chief
Justice Maria Lourdes Sereno.

16.Even having the ample amount of time to apologize for


not abstaining from an offensive party, he even went on
appearing on national interviews ridiculing his critics
and shamming the law along with the Integrated Bar of
the Philippines (IBP). A copy of the article is hereto
attached as Annex 2
17.Atty Lorenzo Gadon’s defense that he was provoked by the
peaceful dissenters finds no merit because videos and
pictures which were televised and circulated in the web
say otherwise.

18.In fact, videos that were circulated online and


televised cement compelling reasons as to why Atty
Lorenzo Gadon should be sanctioned because he blatantly
lied on camera following the incident were he tried to
create fictitious reality saying that he was provoked by
the peaceful dissenters.

19.But even if the dissenters did indeed provoked Atty.


Lorenzo Gadon, he is still required to uphold the
integrity and dignity of the legal profession as
provided by law.

20.Jurisprudence provides that the practice of law is a


privilege however attached with conditions reminding
lawyers to observe that they are 'not [to] engage in
conduct that adversely reflects on his fitness to
practice law, nor shall he whether in public or private
life, behave in a scandalous manner to the discredit of
the legal profession’

21.This would only mean that Atty Lorenzo Gadon, a member


the bar, who waved his middle finger in the against
dissenter while ridiculing the latter with
discriminatory slurs, in essence, is a mockery to the
noble profession in the practice of law.
22.
On violation against Canon 7 in upholding the integrity and dignity
of the legal profession, and its paragraph (3) behavior of a lawyer
as to its private or public life

23.It is a known fact to all lawyers and even law students,


particularly to those who took their Legal Ethics
subject that being a lawyer holds an entitlement of
being a public agent of law attached with public
interest.

24.Atty Lorenzo Gadon finds no sanctuary within the


comforts of Freedom of Expression.

25.He is entitled with his freedoms in Article III Section


4 of the Constitution, but as lawyer and a public agent
who holds public interest, he is not exempted from the
consequences sprouting from his willful and grossly
immoral act which he displayed before the dissenters in
Baguio and the entire Filipino populace.

26.
On Canon 8 conduct of lawyers to their peers prohibiting them use
language which is abusive, offensive or otherwise improper

27.To reiterate, Atty Lorenzo Gadon defense that he was


provoke finds no merit in justifying what he did.

28.In fact, in People vs Noel Villanueva GR No.160351 it


stated that; Following Reyes, and in light of the fact
that there was a perceived provocation coming from
complainant, petitioners act of pointing a dirty finger
at complainant constitutes simple slander by deed.
(Emphasis supplied)

29.Simple slander by deed may not be grossly immoral but


considering the fact that Atty. Lorenzo Gadon is a
lawyer, he holds the responsibility and duty to be
conscious at all times that he is a walking ambassador
of the noble profession of legal practice.

30.Nonetheless, restating what was early above argued,


videos circulated throughout the web and television
visually illustrate that Atty, Lorenzo Gadon was neither
provoked and coerced by the dissenters.

On Violation of the Lawyer’s Oath

31.Atty Lorenzo Gadon, aside from the Canons which he has


violated, need to be reminded of the Lawyer’s Oath.

32.Clearly, Atty Lorenzo Gadon, for the sake of compliance


and passing the Bar, merely memorized the Lawyer’s Oath
without properly discerning its spirit and the
responsibilities and duties he pledged to uphold

33.With this, we end our discussion by enshrining the


Lawyer’s Oath and may it serve it purpose as a beacon of
guidance not only to lawyers but to would-be lawyers
like herein complainants;

I, do solemnly swear that I will maintain allegiance to


the Republic of the Philippines, I will support the
Constitution and obey the laws as well as the legal
orders of the duly constituted authorities therein; I
will do no falsehood, nor consent to the doing of any in
court; I will not wittingly or willingly promote or sue
any groundless, false or unlawful suit, or give aid nor
consent to the same; I will delay no man for money or
malice, and will conduct myself as a lawyer according to
the best of my knowledge and discretion, with all good
fidelity as well to the courts as to my clients; and I
impose upon myself these voluntary obligations without
any mental reservation or purpose of evasion. So help me
God.

PRAYER

WHEREFORE, premises considered, we most respectfully pray that the


Honorable Commission on Bar Discipline:

a. Give due course to this verified complaint;


b. After notice and hearing, recommend to the Board of Governors the
DISBARMENT OF RESPONDENT LORENZO GADON FOR GROSS MISCONDUCT, GROSS
IMMORAL CONDUCT AND VIOLATIONS OF THE LAWYER’S OATH.

RELIEF
In light of the foregoing, it is respectfully prayed that the
instant VERIFIED DISBARMENT COMPLAINT (For violation of 1)Rule 138
Section 20 (f) of the Rules of court, (2) Canon 7.03 of the, (3)
Canon 8.01 of the Code of Professional Responsibility and the (4)
Lawyers Oath) against respondent, Atty. Lorenzo Gadon, be duly noted,
admitted, given due course and granted.

Further, it is respectfully prayed, that judgment be rendered


declaring his guilt and supreme penalty of disbarment be imposed upon
him, ordering that his name be stricken from the Roll of Attorneys,
and punished accordingly.
Other legal and equitable reliefs as may be applicable are
likewise prayed for.

IN WITNESS WHEREOF, I signed this pleading – letter-affidavit-


complaint, this 15th day of September, 2012, at Muntinlupa City.
/
ATTY. _____________________
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