DE LA SALLE UNIVERSITY COLLEGE OF LAW

Lasallian Commission on Bar Operations 2018

LEGAL ETHICS AND PRACTICAL EXERCISES

 Justice Del Castillo
Castillo Digests
Chel Sy Tet Valeza Gel Yatco
LCBO Chairperson Academic Affairs Legal Ethics and Practical
Chairperson Exercises Chairperson
Nico Garcia
LCBO Vice Chair for  Janine Tutanes
Tutanes Donna Santy
Internals Rod Zantua Legal Ethics and Practical
Academic Affairs Deputy Exercises Chairperson
Steph Griar Chairpersons
LCBO Vice Chair for Ian Aquino
Externals RJ Cal
Dane Chua
Pat Costales Nolan Domingo
LCBO Executive Secretary Saibert Sison
Legal Ethics and Practical
Ces Naga Exercises Team Members
LCBO Executive Treasurer
Legal Ethics and Practical Exercises Justice Del Castillo Digests

LEGAL ETHICS

FABIE v. REAL
A.C. No. 10574 | 20 September 2016
Practice of Law

DOCTRINE:  When the integrity of a member of the bar is challenged, he must show proof that he still
maintains that degree of morality and integrity which at all times is expected of him

FACTS:
Fabie claimed to be the owner of a parcel of land under TCT R 1971 which was donated to him by
his sister.
He wanted to return the property so he engaged the services of Real to facilitate the return of
ownership.
Fabie gave Real the Deed of Sale, Deed of Donation, the Xerox and Original of copy of TCT R- 1971,
other documents, and 40,000 for expenses and professional fee. This is evidenced by an
acknowledgement
acknowledgement receipt which had the wrong TCT number (TCT N-129303)
After more than a year, nothing was accomplished by Real. Fabie then asked for the items given to
be returned
Real returned TCT R- 1971but did not return the money and other documents even after demands
made by Fabie.
Fabie filed a complaint against Real
Real’s defense:
He received the mentioned items but they were not given to him to facilitate a transfer but to s ettle
the estate of Fabie’s father. But they weren’t able to do so.
Since they failed to settle the estate, he returned
r eturned the items already which was evidenced by another
acknowledgment
acknowledgment receipt containing the exact same provisions.
The only reason why they filed the complaint is because he was put in the middle of a family spat
He also attached a copy to TCT N-129303
Real also pointed out that Fabie couldn’t have given to him TCT N -129303 since it was reported
missing and was found later than the time the first acknowledgment
acknowledgment receipt was signed.
Fabie’s claims:
The TCT number in the receipt was a typo made by the secretary of Real who typed up the receipt.
Real was able to acquire a copy of TCT N- 129303 from Fabies mother and that he’s he’s now using this
photocopy to negate his bad conduct.
Real denied these claims

ISSUE: Whether or not Real should be suspended for violation of Rule 18?

HELD: Yes, the evidence presented by Real was not sufficient to disprove his guilt.
"The Court has emphatically stated that when the integrity of a member of the bar is
i s challenged, it
is not enough that [he] denies the charges against him; [he] must meet the issue and overcome the
evidence against [him]. [He] must show proof that [he] still maintains that degree of morality and
integrity which at all times is expected of [him]."
Respondent failed in this regard.
Evidence presented by Real is not enough to support his claims. Fabie was able to produce more
convincing evidence.
Because of this, it then appears that his claim that he returned the documents and money is not
credible.

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Legal Ethics and Practical Exercises Justice Del Castillo Digests

ANACTA v. RESURRECCION
A.C. No. 9074 |14 August 2012
Practice of Law

DOCTRINE:  One of the qualifications required of a candidate for admission to the bar is the possession
of good moral character

FACTS:
Anacta engaged and paid for the services of Atty. Resurrecccion for petition for annulment of
marriage before the RTC.
Atty. presented to Anacta a supposed copy of Petition for Annulment of Marriage stamped
“received” by the RTC with a docket number.
Anacta did not hear from respondent. So she made inquiries with the RTC and discovered that
there was no petition filed before the RTC.
Anacta terminated Atty. Resurrecccion’s services for “loss of trust and confidence” and requested
the RTC to refuse any belated attempts to
t o file a petition on her behalf.
Anacta, through new counsel, wrote a letter to demand indemnification for damages Anacta
suffered due to Atty. Resurrecccion’s deceitful acts. Atty Resurrecccion failed to respond.
Anacta then filed a complaint before the IBP praying for disbarment for gross misconduct, deceit,
and malpractice.
IBP directed Atty Resurrecccion to submit and answer- he didn’t.
IBP ruled in favour of Anacta finding Atty. guilty of deceit and dishonesty when he misrepresented
having filed the petition for annulment.

ISSUE: Whether or not respondent should be suspended for violations of the CPR?

HELD: Yes, one of the qualifications required of a candidate for admission to the bar is the possession of
good moral character, and, when one who has already been admitted to the bar clearly shows, by a series
of acts, that he does not follow such moral principles as should govern the conduct of an upright person,
and that, in his dealings with his clients and with the courts, he disregards the rule of professional ethics
required to be observed by every attorney, it is the duty of the court, as guardian of the interests of society,
as well as of the preservation of the ideal standard of professional conduct, to make use of its powers to
deprive him of his professional attributes which he so unworthily abused.
The court is vested with the authority to impose suspension
s uspension in any of the following circumstances:
(1) deceit; (2) malpractice; (3) gross misconduct; (4) grossly immoral conduct; (5) conviction of a
crime involving moral turpitude; (6) violation of the lawyers oath; (7) wilful disobedience of any
lawful order of a superior court; or (8) corruptly or wilfully appearing
appearing as an attorney for a party to
a case without authority to do so.
Clear and convincing evidence presented
presented by Anacta proves that her
h er allegations were true- that he
committed deceitful and dishonest acts by misrepresenting having filed the petition for annulment,
ignoring communications send to him by his client, and ignoring notices sent by the IBP.

ISSUE: Whether or not respondent is guilty of violating Canon 1 of the Code of Professional Responsibility?

HELD: Yes, the acts done by Resurreccion are violative of Rule 1.01.
Rule 1.01 of the Code of Professional Responsibility states that "a lawyer shall not engage in unlawful,
dishonest, immoral or deceitful conduct."
"The Code exacts from lawyers not only a firm respect for law, legal processes but also mandates the utmost
degree of fidelity and good faith in dealing with clients and the moneys entrusted to them pursuant to their
fiduciary relationship."
r elationship."

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Legal Ethics and Practical Exercises Justice Del Castillo Digests

Clear and convincing evidence presented by Anacta proves that her allegations were true- that he
committed deceitful and dishonest acts by misrepresenting having filed the petition for annulment,
ignoring communications send to him by his client, and ignoring notices sent by the IBP.

ANDRES V. NAMBI
A.C. No. 7158 | 9 March 2015
Duties and Responsibilities
Responsibilities of a Lawyer under the Code of Professional Responsibility
Responsibility

DOCTRINE: For there to be gross ignorance of the law, the error must be moved with malice, bad faith,
corruption, fraud and dishonesty.

FACTS:
• Atty. Salimather V. Nambi (Nambi),
(Nambi), as a labor arbiter, rendered a decision against M.A. Mercado
Mercado
Construction and Sps. Maximo and Aida Mercado (Sps. Mercado).
• Sps. Mercado sought to appeal the decision but it was dismissed. As such, an Alias Writ of
Execution was issued against M.A. Mercado Construction to implement the Decision.
• The complainants in the labor case, however, filed an Ex Parte Mortion for Amendment of an Alias
Writ of Execution claiming that they could not collect
collect from M.A. Mercado Construction
Construction because
it transferred all its assets to M.A. Block Work, Inc. As such, they pray that M.A. Mercado
Construction be included in the Writ of Execution.
• Atty Nambi found the Motion to be meritorious and issued an Amended Alias Writ of Execution
to enforce the monetary judgement in the amount of P19,527,623.55 against M.A. Blocks Work,
Inc.
• This prompted the stockholders of M.A. Block Works to file a Complaint for Disbarment against
Atty. Nambi for gross ignorance of the law.

ISSUE: Whether or not Atty. Nambi is guilty

g uilty of gross ignorance of the law for issuing the
t he Amended Alias
writ of Execution?

Held: No, Atty Nambi is not guilty of gross ignorance of the law.
As a rule, for one to be held administratively accountable for gross ignorance of the law, there must be a
showing that the error was gross and patent as to support a conclusion that the actor was so moved with
malice, bad faith, corruption, fraud, and dishonesty.
Based on the order of Atty. Nambi which denied the Urgent Motion to Quash of Andres, Atty. Nambi’s
conclusion had some bases and was not plucked form thin air. Clearly, Atty. Nambi did not act whimsically
or arbitrarily; his ruling oculd not in any manner be characterized as imbued with malice, fraud or bad
faith. His conclusion was reached after an examination of the documents presented and evaluation and
assessment of the arguments raised by the parties. He did not capriciously rule on the issues presented; on
the contrary, he exerted efforts to weigh the positions of the contending parties.
Atty. Nambi should not be held accountable for committing an honest mistake or an error in the
appreciation of the facts of the case before him. Otherwise every labor arbiter or any judicial or quasijudicial
officer for that matter, would be continually plagued with the possibility of being administratively
sanctioned for every honest mistake or error he commits. For sure, this would not augur well to the
administration of justice as a whole.

NOTE: Atty. Nambi was, however, reprimanded for refusing to comply with the lawful order of the court.
Atty. Nambi refused to file a comment despite the court ordering him to do so and he failed to attend the
mandatory conference before the IBP ’s Commission on Bar Discipline.
Di scipline.

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Legal Ethics and Practical Exercises Justice Del Castillo Digests

GABRIEL v. RAMOS
A.M. No. P-06-2256| 10 April 2013
Duties and Responsibilities
Responsibilities of a Lawyer under the Code of Professional Responsibility
Responsibility

DOCTRINE:  We require nothing less than the highest standard of morality and decency for each a nd
every member, from the highest official to the lowest of the rank and file, to preserve the good name and
integrity of courts of justice.

FACTS:
Gabriel filed a complaint against Ramos, who is a sheriff of the RTC of Pasig, for Immorality and
Conduct Unbecoming of a Court Personnel for the ff reasons:
Ramos destroyed personal belongings and fired a gun in the house of his common law wife’s
mother. He was then charged with alarms and scandals and violation of domicile.
 Jenelita is Ramos’ co mmon law wife for 15 years and they have 3 children. Such a relationship
offends the morality and sense of decency of the people in the locality; such conduct violates the
constitution
Ramos argument:
He has been living in the house of his mistress’ mom. H ence, no violation of domicile. They
T hey were
actually removing their things from the house to transfer to another house nearby which the
mother didn’t like. Hence, she filed this case of violation of domicile.
Ramos admitted the common law relationship with Jenelita but denied that it was scandalous and
shocked the common decency- the 15 year dispels any vestiges of immorality and such
circumstances happened out of his place of work and such is not work related. Hence, he cannot
be subject of any administrative action.
These cases filed are to desist him from pursuing criminal acts against Gabriel.
OCA found him to be liable of immorality for his relationship. He was suspended.

ISSUE: Whether or not Ramos is guilty of immorality?

HELD: Yes, he is guilty of disgraceful and immoral conduct. He admission and justification of his
relationship is just proof of his immorality.
Immorality has been defined to include not only sexual matters but also “conducts inconsistent with
rectitude, or indicative of corruption, indecency, depravity, and dissoluteness; or is willful, flagrant or
shameless conduct showing moral indifference to opinions of respectable members
members of the community, and
an inconsiderate attitude toward good order and public welfare.”
The fact that he tried to rationalize it shows his moral indifference.
The illicit relationship between
between a married man and a woman who is not his wife remains illicit – the number
of years don’t matter.
These acts put in question
question his sense of morality, or the standard of morality he lives by. An officer of the
court, and any employee thereof for that matter, should be above reproach. The very existence of the court,
the institution we represent, is anchored
anchored on upholding what is true, right and just. That is why we require
nothing less than the highest standard of morality and decency for each and every member, from the
highest official to the lowest of the rank and file, to preserve the good name and integrity of courts of justice,
lest we be deemed unworthy to represent this thi s honorable institution.

MAGSAYSAY MARITIME CORPORATION v. VIRGILIO L. MAZAREDO

G.R. No. 201359 | 23 September 2015
Duties and Responsibilities
Responsibilities of a Lawyer under the Code of Professional Responsibility
Responsibility

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DOCTRINE:  Lawyers should not willfully and intentionally resort to falsehood and deception in order to
misguide, obstruct and impede the proper administration of justice.

FACTS:
Virgilio L. Mazaredo (Mazaredo) is an employee of Magsaysay Maritime Corporation (Magsaysay). He
was assigned to MV Tahitan
T ahitan Princess where he was medically repatriated.
Mazaredo was diagnosed to be suffering from coronary artery disease, three-vessel involvement and he
was made to undergo angioplasty.
After the operation, Mazaredo filed a complaint against Magsaysay for recovery of permanent total
disability and sickness benefits.
The counsels of Magsaysay, Attorneys Herbert A. Tria (Tria) and Jerome Pampolina (Pampolina)
repeatedly attempted to mislead the LA, the NLRC, the CA and the SC that a “Medical Report” was issued
by the company-designated
company-designated physician stating that Mazaredo’s condition was not work related.

ISSUE: Whether or not Atty. Tria and Pampolina should be subjected to disciplinary action for attempting
to deceive the court?

HELD: Yes, Atty. Tria and Pampolina should be disciplined. Tria and Pampolina continued to refer to the
document “Medical Report” in their pleadings when it appears in truth and in fact that there is no such
document. It would appear, therefore, that such medical report was contrived in order to satisfy the legal
requirement that the company-designated
company- designated physician must make a definitive assessment of the employee’s
fitness to work in order to justify a denial of disability benefits.
The Code of Professional Responsibility provides that "[a] lawyer shall not engage in unlawful,
dishonest, immoral or deceitful conduct" (Rule 1.01); he "shall not, for any corrupt motive or
interest, encourage any suit or proceeding or delay any man's cause" (Rule 1.03); he "shall not do
any falsehood, nor consent to the doing of any in Court, nor shall he mislead, or allow the Court to
be misled by any artifice" (Rule 10.01); and he "shall not knowingly x x x assert as a fact that which
has not been proved" (Rule 10.02).
Lawyers should not transcend the bounds of propriety and commit a travesty before the Court by
willfully, intentionally and deliberately resorting to falsehood and deception in handling their
client’s case in order to misguide, obstruct and impede the proper adm inistration of justice.

PLAZA v. AMAMIO
A.M. No. P-08-2559 | 19 March 2010
Duties and Responsibilities
Responsibilities of a Lawyer under the Code of Professional Responsibility
Responsibility

DOCTRINE:  The court and its premises shall be used exclusively for court or judicial functions and not for
any other purpose. As temples of justice, their dignity and sanctity must be preserved at all times.

FACTS:
Plaza (Clerk of Court) filed a complaint against Atty. Amamio, Vasquez (Legal Researcher) and
Patalinghug (Court Stenpgrapher) for allowing a party and raffle draw to be held by Sara Lee
(Beauty and Fashion products) in the Hall of Justice of Argao Cebu in violation of Administrative
Circular No. 3-92 which prohibits the use of the of the Hall of Justice for commercial or residential
purposes.
The respondents did not deny allowing the party to be held and arg ue that the Hall of Justice had
been used in similar ways in the past claiming that a beauty pageant was held at the front of the
Hall and the ground floor lobby was used; that the Hall had also been used in a Sinulog festival
when onlookers used the stairs and the second
s econd floor to watch the parade and performances in the
Plaza.

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Legal Ethics and Practical Exercises Justice Del Castillo Digests

They accused also claimed the Hall is a cultural heritage and the centerpiece of the municipality,
thus the activities which was planned by Sara Lee was appropriate
ap propriate in promoting the municipality
of Argao; that it was appropriate to show
s how the building to visitors who wanted to visit and see the
building. Finally the respondents claim that they acted in the best of their abilities, acted in good
faith, without malice, and had no intention to prejudice the interests of the court.
The RTC made a recommendation of dismissing the case for a lack of substantial evidence to
substantiate the charge while the OCA found to the contrary finding the respondents violated
Admin Circular No. 3-92 by allowing a raffle draw in the lobby of the Argao Hall of Justice,
recommending Atty. Amamoio to be SUSPENDED, Vasquez and Patalinghug

ISSUE: Whether or not the defendants disrespected the courts for violating Administrative Circular 3-92
when they allowed Sara Lee to hold a party and
a nd raffle draw in the ground floor lobby of the Hall of Justice.
J ustice.

HELD: Yes, the holding of a raffle draw at the Argao Hall of Justice by the staff of Sara Lee degraded the
honor and dignity of the court and exposed the premises, as well as the judicial records to danger of loss
or damage. In Administrative Circular No. 3-92, we have already reminded all judges and court personnel
that "the Halls of Justice may be used only for purposes directly related to the functioning and operation
of the courts of justice, and may not be devoted to any other use
The Argao Hall of Justice is not meant to be used for festivities, and in fact should remain closed to the
public during such occasions.
The contention that there was no danger to the building and the records since the raffle draw was merely
held at the ground floor lobby and that those who attended the raffle draw were decent people, majority
of whom are women, is untenable.
Time and again, the Court has always stressed
st ressed in pertinent issuances and decisions that courts are temples
of justice, the honor and dignity of which must be upheld and that their use shall not expose judicial records
to danger of loss or damage. So strict is the Court about this that it has declared that the prohibition against
the use of Halls of Justice for purposes other than that for which they have been built extends to their
immediate vicinity including their grounds.
If the building housing the Argao Hall of Justice is such an important historical landmark, all the more
reason why activities, such as Sara Lee raffle draw, should not be held within. At most, the said Hall of
 Justice could
could have been made part of a regular local tour, to be viewed at designated hours, which
which viewing
shall be confined to certain areas not intrusive to court operations and records.

DAVAO IMPORT DISTRIBUTORS v. LANDERO

A.C. No. 5116 | 13 April 2015
Duties and Responsibilities
Responsibilities of a Lawyer under the Code of Professional Responsibility
Responsibility

DOCTRINE:  An attorney is bound to protect his client's interest to the best of his ability and with utmost
diligence

FACTS:
Davao Import Distributors, Inc. engaged the services of Atty. Landero to file a Complaint against for the
recovery of one split type air-conditioner
air -conditioner with replevin
replevin and damages.
On the scheduled date of pre-trial, Atty. Landero failed to appear. And since he also failed to inform Davao
Dav ao
of the scheduled pre-trial, they too were unable to attend. As a result, the case was dismissed for non-suit.
MTCC issued a Decision ordering Davao to pay moral damages, attorney's fees and litigation expenses.
Without filing a Motion for Reconsideration, Atty. Landero appealed the MT CC Decision to the Regional
Trial Court (RTC). RTC issued its Decision affirming the MTCC Decision.

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Davao then disbursed money to Atty. Landero so that he may file a petition for review before the Court of
Appeals. Initially, he file for
for extension. However, he failed to file the same such that the CA dismissed the
appeal.
Hence, a Complaint for Disbarment was filed where Davao asserts that Atty. Landero's actuations of (1)
not appearing in the pre-trial of the case, (2) not availing of the legal remedies against the dismissal of the
Complaint due to non-suit, and (3) failing to file a petition for review, constitute unprofessional behavior
or misconduct and violations of Canon 12 of the CPR, which merit disciplinary action, if not, disbarment.

ISSUE: Whether or not the defendants

d efendants violated the CPR by neglecting his client’s case

HELD: Yes, a lawyer is first and foremost an officer of the court. While he owes his entire devotion to the
interest and causes of his client, he must ensure that he acts within the bounds of reason and common
sense, always aware that he is an instrument of truth and justice.
As an officer of the court and its indispensable partner in the sacred task of administering justice, graver
responsibility is imposed upon a lawyer than any other to uphold the integrity of the courts and to show
respect to its processes. Any act on his part which tends visibly to obstruct, pervert or impede and degrade
the administration of justice constitutes professional misconduct calling for the exercise of disciplinary
action against him.

CAOILE v. MACARAEG
AC No. 720 | 17 June 2015
Duties and Responsibilities
Responsibilities of a Lawyer under the Code of Professional Responsibility
Responsibility

DOCTRINE: A motion for extension to file an appellant’s brief carries with it the presumption that the
applicant-lawyer
applicant-lawyer will file the pleading within the requested extended period. Failure to do so without any
reasonable excuse violates the Code of Professional Responsibility.

FACTS:
This is a Disbarment case filed by Caoile against Atty. Macaraeg for neglect and dereliction of duty.
Caoile alleged that:
Along with four others, they engaged the services of Atty. Macaraeg in an action for recovery of
ownership filed before the CFI of Lingayen, Pangasinan;
CFI rendered a judgment AGAINST them, so, Caoile et al decided to appeal before the CA;
Atty. Macaraeg filed a Notice o f Appeal; he moved for extension of time to file the Caoile’s brief;
in the last motion for extension, Atty. Macaraeg alleged that he was already
alr eady in the process of doing
the finishing touches on the brief and just needed to have it printed. Yet, the extended period
expired without Atty. Macaraeg filing any brief.
The CA, dismissed the appeal and such became final and executory.
Caoile et al were not aware of the dismissal until they were served with the CFI’s writ of Execution
and a Notice of Sale at public auction of their property.
When Caoile confronted Atty. Macaraeg about the dismissal of the case, Att y. Macaraeg told them
that it was because he was not paid in full for his services in filing the appeal.
Atty. Macaraeg denied Francisco’s accusation that  he neglected their case. He pointed out that:
to push through with the appeal he even a dvanced some of the appeal expenses.
While he admitted that he failed to submit an appellants’ brief, he averred that the same was
actually the fault of his clients who failed to provide the necessary funds to file said
s aid brief.
He constantly reminded Francisco to give him the amount necessary to cover the costs of the
transcript and printing of the appeal brief.

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He even filed three motions for extension of time to file brief to give Francisco more time to come
up with the said payment. Still, Francisco was unable to pay.

ISSUE: Whether or not Atty. Macaraeg violated

v iolated Rule 12.03 of the Code of Professional Responsibility?

HELD: Yes, if Atty. Macaraeg truly

tr uly believed that the necessary funds from his clients were not forthcoming,
he could have excused himself from the case. The Code of Professional Responsibility allows a counsel to
withdraw his services for a good cause, including the client’s failure to comply with t he retainer agreement.
● A motion for extension to file an appellant’s brief carries with it the presumption that the applicant -
lawyer will file the pleading within the requested extended period. Failure to do so without any
reasonable excuse violates the Code of Professional Responsibility.
● The court, however, dismissed the petitioner’s complaint for disbarment because the complainant
had already lost interest in pursuing this disbarment case against Atty. Macaraeg and that there is
truth in the handwritten notation in the return of the subpoena that Atty. Macaraeg had already
passed away.

SALABAO v. VILLARUEL
A.C. No. 8084 | 24 August 2015
Duties and Responsibilities
Responsibilities of a Lawyer under the Code of Professional Responsibility
Responsibility

DOCTRINE:  While it is true that lawyers owe "entire devotion" to the cause of their clients, it cannot be
emphasized enough that their first and primary duty is "not to the client but to the administration of
 justice."

FACTS:
● Salabao filed a case against Lumberio for his deceitful or fraudulent conduct of taking her real
property. Lumberio was represented by respondent Atty. Villaruel.
● The RTC ruled in her favor.
● In order to delay the case, Villaruel appealed to the CA and later again to the SC. The SC still ruled
in favor of Salabao. The
T he decision became final and executory.
● Undeterred, Villaruel further tried to defer the execution of the decision by brining a Petition for
Annulment of Judgment of the RTC to the CA. He lost again and appealed to the SC S C with clear or
new arguments other than what he h e had presented before the CA.
● Still, Villaruel filed a Petition for Certiorari seeking
seeking to annul the Order of t he RTC before the Court
of Appeals which was dismissed.
● He filed a new complaint before the RTC and filed several Motions for Inhibition and Contempt
that were meant to delay the
th e resolution of the case.
● He likewise filed an administrative case against the Judge of the RTC which denied the second
attempt to delay the execution of the SC decision.
● Salabao complained that Villaruel made her suffer
suffer because of his abuse of processes and disregard
for her rights as a litigant- that Villaruel had done more than enough to suppress her rights as a
winning litigant and filed this case for abuse of processes pursuant to Rule 10.03 and Rule 10.02
1 0.02 of
Canon 10 and Rule 12.04 of Canon 12 of the Code of Professional Responsibility (CPR).
(CPR).
● Atty. Villaruel denied the accusation and clarified that to his mind, the said his actions are
completely justified under the Rules of Court.

ISSUE: Whether or not

not the defendants disrespected Violated the CPR and the
th e Lawyer’s Oath.

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