9. BUGARING AND ROYAL BECHTEL BUILDERS, INC. vs. HON. DOLORES S.

ESPAÑOL, 349 SCRA 687, January 19,

2001
FACTS:
The incident subject of the petition occurred during a hearing of Civil Case entitled "Royal
Becthel Builders, Inc. vs. Spouses Luis Alvaran and Beatriz Alvaran, et al.", for Annulment of Sale and Certificates
of Title, Specific Performance and Damages with Prayer for Preliminary Injunction and/or Temporary Restraining
Order in the sala of respondent judge Dolores S. Español of the Regional Trial Court of Cavite, Branch 90, Imus,
Cavite.
Atty. Rexie Efren A. Bugaring was counsel for Royal Bechtel Builders against Spouses Luis and Beatriz Alvaran on a case for
annulment Certificates of Title, Specific Performance and Damages with Prayer for Preliminary Injunction or Temporary Restraining
Order. In one of the hearings, he was cited for contempt for allegedly bringing an assistant in court to document
the hearing on video tape and being disrespectful to the court. That while Atty. Concepcion, a respondent called on
his lawyer, Atty. Barzaga to proceed on behalf of his client, Atty. Bugaring insisted that he be allowed to present his
documentary evidence. He would then interrupt the court by insisting that he be allowed to present his evidence. The Court told
him a few times to listen and yet he would speak up, often in a sarcastic manner anytime he feels like. He also
mentioned about he is more rather knowledgeable on the rules of Court. He also accused the Judge of being
antagonistic towards his client
ISSUE:
Whether or not Atty. Bugaring should be cited for contempt.
RULING:
Yes. Atty. Bugaring was cited for contempt, sentenced to three days in jail with a fine of P 3,000. However, appellate court
ordered that P 1,000 be returned as it exceeds the P 2,000 limit.
The Court agrees with the appellate court. It contends that a lawyer should not be carried away in espousing his client’s
cause. He should not forget that he is an officer of the court, bound to extend every effort and placed under
duty, to assist in the speedy and efficient administration of justice pursuant to Canon 12 of the Code of
Professional Responsibility. He should not therefore misuse the rules of procedure to defeat the ends of justice. Lawyers
should be reminded that their primary duty is to assist the courts in the administration of justice. Any conduct
which tends to delay, impede or obstruct the administration of justice contravenes such lawyer’s duty.