73555208-CAYETANO-VS-MONSOD

8/3/2019 73555208-CAYETANO-VS-MONSOD

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CAYETANO VS MONSOD

FACTS:

Respondent Christian Monsod was nominated byPresident Corazon C. Aquino to the position ofchairman of the COMELEC. Petitioner opposed thenomination because allegedly Monsod does notpossess required qualification of having been

engaged in the practice of law for at least tenyears. The 1987 constitution provides in Section1, Article IX-C: There shall be a Commission onElections composed of a Chairman and sixCommissioners who shall be natural-born citizensof the Philippines and, at the time of theirappointment, at least thirty-five years of age,holders of a college degree, and must not havebeen candidates for any elective position in theimmediately preceding elections. However, amajority thereof, including the Chairman, shall bemembers of the Philippine Bar who have beenengaged in the practice of law for at least ten

years.

ISSUE:It is whether the respondent has the ten yearpractice of law requirement for him to assumesuch office

HELD:Practice of law means any activity, in or out ofcourt, which requires the application of law, legalprocedure, knowledge, training and experience."To engage in the practice of law is to performthose acts which are characteristics of theprofession. Generally, to practice law is to givenotice or render any kind of service, which deviceor service requires the use in any degree of legalknowledge or skill.

In general, a practice of law requires a lawyer andclient relationship, it is whether in or out of court.Atty. Monsod's past work experiences as alawyer-economist, a lawyer-manager, a lawyer-entrepreneur of industry, a lawyer-negotiator ofcontracts, and a lawyer-legislator of both the richand the poor verily more than satisfy theconstitutional requirement that he has beenengaged in the practice of law for at least tenyears.

MANIAGO VS DE DIOS

Complainant alleged that she filed acriminal case against a Japanese national. Theaccused was represented by Atty. De Dios.

Complainant then learned from the RTCstaff that Atty. De Dios had an outstandingsuspension order from the Supreme Court since2001, and was, therefore, prohibited from

appearing in court. Complainant averredthat Atty. De Dios ought to be disbarred fromthe practice of law for her flagrant violation anddeliberate disobedience of a lawful order of theSupreme Court.

In her Comment, Atty. De Dios admittedthat there were cases filed against her client,Miyata. She, however, denied that she was undersuspension when she appeared as his counsel inthe cases.

Respondent explained that anadministrative case was indeed filed against herwhere she was meted the penalty of 6-monthsuspension. She served the suspensionimmediately upon receipt of the CourtsResolution on May 16, 2001 up to November 16,2001. In a Manifestation filed on October 19,2001, respondent formally informed the Courtthat she was resuming her practice of law onNovember 17, 2001, which she actually did.

A problem arose when Judge Josefina

Farrales, in her capacity as Acting ExecutiveJudge of the RTC, Olongapo City, erroneouslyissued a directive on March 15, 2007,ordering respondent to desist from practicing lawand revoking her notarial commission for theyears 2007 and 2008. Knowing that the directivewas rather questionable, respondent,nonetheless, desisted from law practice in duedeference to the court order. Thereafter,respondent filed a Motion for Clarification withthe Supreme Court on account of Judge Farralesletters to all courts in Olongapo City and to some

municipalities in Zambales, which gave theimpression that Atty. De Dios is not yet allowedto resume her practice of law and that hernotarial commission for the years 2007 and 2008is revoked.

Respondent averred that for the period stated inthe affidavit of complainant Maniago, duringwhich she allegedly practiced law, she wasneither suspended nor in any way prohibited frompractice. The complaint, she added, wasbaseless and malicious, and should be dismissedoutright.

Thus, according to the OBC, a suspendedlawyer must first present proof(s) of hiscompliance by submitting certifications from theIntegrated Bar of the Philippines and from theExecutive Judge that he has indeed desisted fromthe practice of law during the period ofsuspension. Thereafter, the Court, afterevaluation, and upon a favorablerecommendation from the OBC, will issue aresolution lifting the order of suspension and thusallow him to resume the practice of law. The OBC


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alleged that it was unfortunate that thisprocedure was overlooked in A.C. No. 4943,where Atty. De Dios was able to resume herpractice of law without submitting the requiredcertifications and passing through the OBC forevaluation. In order to avoid confusion andconflicting directives from the Court, the OBCrecommended that the Court adopt a uniformpolicy on the matter of the lifting of the order ofsuspension of a lawyer from the practice of law.

The Court notes the Report andRecommendation of the OBC.

It must be remembered that the practice

of law is not a right but a mere privilege and, assuch, must bow to the inherent regulatory powerof the Supreme Court to exact compliance withthe lawyers public responsibilities.[3] Whenever itis made to appear that an attorney is no longerworthy of the trust and confidence of his clientsand of the public, it becomes not only the rightbut also the duty of the Supreme Court, whichmade him one of its officers and gave him theprivilege of ministering within its Bar, to withdrawthat privilege.[4] However, as much as the Courtwill not hesitate to discipline an erring lawyer, itshould, at the same time, also ensure that alawyer may not be deprived of the freedom andright to exercise his profession unreasonably.

PETITION FOR LEAVE TO RESUME PRACTICEOF LAW of BENJAMIN M. DACANAY

Facts:

Petitioner was admitted to the Philippine bar inMarch 1960. He practiced law until he migratedto Canada in December 1998 to seek medicalattention for his ailments. He subsequentlyapplied for Canadian citizenship to avail ofCanadas free medical aid program. Hisapplication was approved and he became aCanadian citizen in May 2004.

On July 14, 2006, pursuant to Republic Act (RA)9225 (Citizenship Retention and Re-AcquisitionAct of 2003), petitioner reacquired his Philippine

citizenship. On that day, he took his oath ofallegiance as a Filipino citizen before thePhilippine Consulate General in Toronto, Canada.

Thereafter, he returned to the Philippines andnow intends to resume his law practice.

Issue:

WON petitioner may still resume practice? YES

Held:

Section 2, Rule 138 of the Rules of Court providesan applicant for admission to the bar be a citizenof the Philippines, at least twenty-one years ofage, of good moral character and a resident ofthe Philippines.5 He must also produce beforethis Court satisfactory evidence of good moralcharacter and that no charges against him,involving moral turpitude, have been filed or arepending in any court in the Philippines.

Since Filipino citizenship is a requirement foradmission to the bar, loss thereof terminatesmembership in the Philippine bar and,consequently, the privilege to engage in thepractice of law. In other words, the loss of Filipinocitizenship ipso jure terminates the privilege topractice law in the Philippines. The practice of lawis a privilege denied to foreigners.

The exception is when Filipino citizenship is lostby reason of naturalization as a citizen of anothercountry but subsequently reacquired pursuant toRA 9225. This is because all Philippine citizenswho become citizens of another country shall bedeemed not to have lost their Philippinecitizenship under the conditions of [RA 9225].

Therefore, a Filipino lawyer who becomes acitizen of another country is deemed never tohave lost his Philippine citizenship if hereacquires it in accordance with RA 9225.

Before he can can resume his law practice, hemust first secure from this Court the authority todo so, conditioned on:o the updating and payment of of IBPmembership dues;o the payment of professional tax;o the completion of at least 36 credit hours ofmandatory continuing legal education; this isspecially significant to refresh theapplicant/petitioners knowledge of Philippinelaws and update him of legal developments andof the retaking of the lawyers oath.

In re: CUNANANFacts:

Congress passed Republic Act Number 972,commonly known as the Bar Flunkers Act of

1953. In accordance with the said law, theSupreme Court then passed and admitted to thebar those candidates who had obtained anaverage of 72 per cent by raising it to 75 percent.

After its approval, many of the unsuccessfulpostwar candidates filed petitions for admissionto the bar invoking its provisions, while othermotions for the revision of their examinationpapers were still pending also invoked theaforesaid law as an additional ground foradmission. There are also others who have
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sought simply the reconsideration of their gradeswithout, however, invoking the law in question.

To avoid injustice to individual petitioners, thecourt first reviewed the motions forreconsideration, irrespective of whether or notthey had invoked Republic Act No. 972.

Issue:

WON RA No. 972 is constitutional and valid? NO

Held:

RA No. 972 has for its object, according to itsauthor, to admit to the Bar, those candidates whosuffered from insufficiency of reading materialsand inadequate preparation.

In the judicial system from which ours has beenevolved, the admission, suspension, disbarmentand reinstatement of attorneys at law in thepractice of the profession and their supervisionhave been indisputably a judicial function andresponsibility. We have said that in the judicialsystem from which ours has been derived, theadmission, suspension, disbarment orreinstatement of attorneys at law in the practiceof the profession is concededly judicial.

The power of admitting an attorney to practicehaving been perpetually exercised by the courts,it having been so generally held that the act ofthe court in admitting an attorney to practice isthe judgment of the court, and an attempt as thison the part of the Legislature to confer such rightupon any one being most exceedinglyuncommon, it seems clear that the licensing of anattorney is and always has been a purely judicialfunction, no matter where the power todetermine the qualifications may reside.

On this matter, there is certainly a cleardistinction between the functions of the judicialand legislative departments of the government.

It is obvious, therefore, that the ultimate power togrant license for the practice of law belongsexclusively to this Court, and the law passed byCongress on the matter is of permissivecharacter, or as other authorities may say,merely to fix the minimum conditions for thelicense.

IN RE: VICTORIO D. LANUEVO

Facts:

This is a disbarment matter with regards toAttorney Victorio Lanuevo, the Bar Confidant forthe 1971 Bar Examinations. Supreme Courtreceived a confidential letter that speaks of the

exam notebooks of a examinee named RamonGalang who has been re-evaluated and re-corrected such that he hurdled the Bar Examsand was admitted to the Bar.

Lanuevo admitted having brought the fiveexamination notebooks of Ramon E. Galang backto the respective examiners for re-evalution or rechecking. The five examiners admitted having re-evaluated or re-checked the notebook to him bythe Bar Confidant, stating that he has theauthority to do the same and that the examineeconcerned failed only in his particular subject andwas on the borderline of passing. Ramon Galangwas able to pass the 1971 bar exam because ofLanuevos move but the exam results bears thathe failed in 5 subjects namely in (Political, Civil,Mercantile, Criminal & Remedial).

Galang on the otherhand, denied of havingcharged of Slight Physical Injuries on Eufrosino deVera, a law student of MLQU.

The five examiners were led by Lanuevo tobelieve that it is the Bar Committees regularactivity that when an examinee has failed in onesubject alone, the rest he passed, the examinerin that subject which he flunked will review hisexam notebook.

Afterwards, Lanuevo gained possession of fewproperties, including that of a house in BF Homeswhich was never declared in his declaration ofassets and liabilities.

Issue:

WON Lanuevo was guilty of defrauding theexaminers such that Galang passed the Bar? YES

Held:

It was plain, simple and unmitigated deceptionthat characterized respondent Lanuevos well-studied and well-calculated moves in successivelyrepresenting separately to each of the fiveexaminers concerned to the effect that theexaminee failed only in his particular subjectand/or was on the borderline of passing. Torepeat, the before the unauthorized re-evaluations were made, Galang failed in the five(5) major subjects and in two (2) minor subjectswhich under no circumstances or standard couldit be honestly claimed that the examinee failedonly in one, or he was on the borderline ofpassing.

The Bar Confidant has absolutely nothing to do inthe re-evaluation or reconsideration of the gradesof examinees who fail to make the passing markbefore or after their notebooks are submitted to it


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by the Examiners. The Bar Confidant has nobusiness evaluating the answers of theexaminees and cannot assume the functions ofpassing upon the appraisal made by theExaminers concerned. He is not the over-allExaminer. He cannot presume to know betterthan the examiner.

AS TO GALANGS CRIM CASE: The concealment ofan attorney in his application to take the Barexaminations of the fact that he had beencharged with, or indicted for, an alleged crime, isa ground for revocation of his license to practicelaw is well settled. The practice of the law isnot an absolute right to be granted every onewho demands it, but is a privilege to be extendedor withheld in the exercise of sound discretion.

The standards of the legal profession are notsatisfied by conduct which merely enables one toescape the penalties of the criminal law.

Under the circumstances in which respondentRamon E. Galang, alias Roman E. Galang, wasallowed to take the Bar examinations and thehighly irregular manner in which he passed theBar, WE have no other alternative but to orderthe surrender of his attorneys certificate and thestriking out of his name from the Roll ofAttorneys.

In the Matter of the IBP Membership DuesDelinquency of Atty. MARCIAL A. EDILION

Facts:

The respondent Marcial A. Edillon is a dulylicensed practicing attorney in the Philippines.

The IBP Board of Governors recommended to theCourt the removal of the name of the respondentfrom its Roll of Attorneys for stubborn refusal topay his membership dues to the IBP since thelatters constitution notwithstanding due notice.

Edilion contends that the provision providing forthe IBP dues constitute an invasion of hisconstitutional rights in the sense that he is beingcompelled, as a pre-condition to maintaining hisstatus as a lawyer in good standing, to be a

member of the IBP and to pay the correspondingdues, and that as a consequence of thiscompelled financial support of the saidorganization to which he is admittedly personallyantagonistic, he is being deprived of the rights toliberty and property guaranteed to him by theConstitution. Hence, the respondent concludes,the above provisions of the Court Rule and of theIBP By-Laws are void and of no legal force andeffect.

Issue:

WON the payment of IBP dues suffersconstitutional infirmity? NO

Held:

All legislation directing the integration of the Barhave been uniformly and universally sustained asa valid exercise of the police power over animportant profession.

The practice of law is not a vested right but aprivilege, a privilege moreover clothed with publicinterest because a lawyer owes substantial dutiesnot only to his client, but also to his brethren inthe profession, to the courts, and to the nation,and takes part in one of the most importantfunctions of the State the administration of

justice as an officer of the court.

When the respondent Edillon entered upon thelegal profession, his practice of law and hisexercise of the said profession, which affect thesociety at large, were (and are) subject to thepower of the body politic to require him toconform to such regulations as might beestablished by the proper authorities for thecommon good, even to the extent of interferingwith some of his liberties. If he did not wish tosubmit himself to such reasonable interferenceand regulation, he should not have clothed thepublic with an interest in his concerns.

To compel a lawyer to be a member of theIntegrated Bar is not violative of his constitutionafreedom to associate. 6

Bar integration does not compel the lawyer toassociate with anyone. He is free to attend or notattend the meetings of his Integrated Bar Chapteror vote or refuse to vote in its elections as hechooses. The only compulsion to which he issubjected is the payment of annual dues. TheSupreme Court, in order to further the Stateslegitimate interest in elevating the quality ofprofessional legal services, may require that thecost of improving the profession in this fashion beshared by the subjects and beneficiaries of theregulatory program the lawyers.

Such compulsion is justified as an exercise of thepolice power of the State. Why? The right topractise law before the courts of this countryshould be and is a matter subject to regulationand inquiry. And, if the power to impose the feeas a regulatory measure is recognize, then apenalty designed to enforce its payment, whichpenalty may be avoided altogether by payment,is not void as unreasonable or arbitrary.

LETTER OF ATTY. CECILIO Y. AREVALO, JR.,REQUESTING EXEMPTION FROM PAYMENT


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OF IBP DUES

Facts:

Petitioner sought exemption from payment of IBPdues in the amount of P12,035.00 as allegedunpaid accountability for the years 1977-2005.

He alleged that after being admitted to thePhilippine Bar in 1961, he became part of thePhilippine Civil Service from July 1962 until 1986,then migrated to, and worked in, the USA inDecember 1986 until his retirement in the year2003.

He maintained that he cannot be assessed IBPdues for the years that he was working in thePhilippine Civil Service since the Civil Service lawprohibits the practice of ones profession while ingovernment service, and neither can he beassessed for the years when he was working inthe USA.

He also posits that compulsory payment of theIBP annual membership dues would indubitablybe oppressive to him considering that he hasbeen in an inactive status and is without incomederived from his law practice. He adds that hisremoval from nonpayment of annual membershipdues would constitute deprivation of propertyright without due process of law. Lastly, he claimsthat non-practice of law by a lawyer-member ininactive status is neither injurious to active lawpractitioners, to fellow lawyers in inactive status,nor to the community where the inactive lawyers-members reside.

Issue:

WON petitioner is entitled to exemption frompayment of his dues during the time that he wasinactive in the practice of law? NO

Held:

There is nothing in the Constitution that prohibitsthe Court, under its constitutional power and dutyto promulgate rules concerning the admission tothe practice of law and in the integration of thePhilippine Bar which power required membersof a privileged class, such as lawyers are, to paya reasonable fee toward defraying the expensesof regulation of the profession to which theybelong. It is quite apparent that the fee is,indeed, imposed as a regulatory measure,designed to raise funds for carrying out the nobleobjectives and purposes of integration.

Payment of dues is a necessary consequence ofmembership in the IBP, of which no one is

exempt. This means that the compulsory natureof payment of dues subsists for as long as onesmembership in the IBP remains regardless of thelack of practice of, or the type of practice, themember is engaged in.

There is nothing in the law or rules which allowsexemption from payment of membership dues. Atmost, as correctly observed by the IBP, he couldhave informed the Secretary of the IntegratedBar of his intention to stay abroad before he left.In such case, his membership in the IBP couldhave been terminated and his obligation to paydues could have been discontinued.

DECISION: DENIED.

ST. LOUIS UNIVERSITY LABORATORY vs.ATTY. ROLANDO C. DELA CRUZ

Facts:This is a disbarment case filed by the Facultymembers and Staff of the Saint Louis University-Laboratory High School (SLU-LHS) against Atty.Rolando C. Dela Cruz, principal of SLU-LHS, for:(a) pending criminal case for child abuse and alabor case against him in the NLRC(b) contracting a second marriage despite theexistence of his first marriage(c) notarizing documents despite the expiration ohis commission

Issue:

WON Atty. Dela Cruz must be disbarred? NO,SUSPENSION ONLY

Held:

A disbarment case is sui generis for it is neitherpurely civil nor purely criminal but is rather aninvestigation by the court into the conduct of itsofficers. Thus, if the acquittal of a lawyer in acriminal action is not determinative of anadministrative case against him, or if an affidavitof withdrawal of a disbarment case does notaffect its course, then neither will the judgment ofannulment of respondents second marriage alsoexonerate him from a wrongdoing actuallycommitted. So long as the quantum of proof clear preponderance of evidence in disciplinaryproceedings against members of the Bar is met,then liability attaches.

Section 27, Rule 138 of the Rules of Court citesgrossly immoral conduct as a ground fordisbarment. Immoral conduct is that conductwhich is willful, flagrant, or shameless, and whichshows a moral indifference to the opinion of thegood and respectable members of the


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community and what is grossly immoral, thatis, it must be so corrupt and false as to constitutea criminal act or so unprincipled as to bereprehensible to a high degree.

Yes, there was immoral conduct. But, it was notas gross as to warrant his disbarment because:(a) His second marriage was a show of his nobleintentions and total love for his wife(b) He never absconded from his obligations tosupport his wife and child(c) After his first failed marriage and prior to hissecond marriage or for a period of almost seven(7) years, he has not been romantically involvedwith any woman(d) Since then up to now, respondent remainedcelibate.

Notarization is not an empty, meaningless,routinary act. On the contrary, it is invested withsubstantive public interest, such that only thosewho are qualified or authorized may act asnotaries public. Notarization of a privatedocument converts the document into a publicone making it admissible in court without furtherproof of its authenticity. A notarial document isby law entitled to full faith and credit upon itsface and, for this reason, notaries public mustobserve with the utmost care the basicrequirements in the performance of their duties.

DECISION: 4 YEARS SUSPENSION ONLY.

DOROTEO IGOY vs. ATTY. GILBERT SORIANO

Facts:

Doroteo A. Igoy is one of the petitioners in a civilcase entitled Heirs of Gavino Igoy, et al. v.Mactan Shangrila Hotel.

Complainant said that while the aforesaid casewas still pending before the Court of Appeals, hetried to look for a person in the Supreme Courtwho may assist him in obtaining justice. A friendintroduced complainant to a certain Justice ofthe Supreme Court, which was Atty. Soriano. Henarrated to the said Justice the history of theircase. In turn, the said Justice asked for andreceived from him the sum of P20K. However, thesaid Justice reminded complainant that he couldoffer no help while the case was pending beforethe Court of Appeals.

They lost in the CA. So Soriano prepared thepetition for review to be filed with the SupremeCourt. He asked for another P20K. As promisedthe money was delivered, which was claimed bySorianos son.

Soriano denies the money given, saying that itwas only a token.

Soon, Soriano resigned from his office.

Issue:

WON Soriano committed acts which will warranthis disbarment? YES

Held:

The claim of Atty. Soriano that the amount wasgiven gratuitously would not excuse him from anyliability. To tolerate such acts would open thefloodgates to fraud or graft and corruption to becommitted by officials and employees of theCourt.

It is admitted that respondent offered to resign,however, resignation should not be used as aneasy way to escape administrative liability by a

court personnel facing administrative sanction.Respondent therefore cannot go scot-free and besimply forgiven for the damage he caused to theinstitution he was bound by his oath and TheCanons of Legal Ethics to serve with utmostintegrity.

Respondent may have been in the service for 28years, but he has blemished his recordirreparably and under the circumstances, thisoffice believes that dismissal as a penalty iswarranted.

The nature and responsibilities of public officersenshrined in the Constitution are not mererhetorical words to be taken lightly as idealisticsentiments but as working standards andattainable goals that should be matched withactual deeds. Those involved in theadministration of justice must live up to thestrictest standards of honesty and integrity in thepublic service.

What makes his infraction worse is the fact thathe is not a mere court employee, but a seniorattorney employed in the Highest Court of theLand. He has indelibly sullied his record ofgovernment service spanning twenty-eight years,and in so doing he has prejudiced the integrity ofthe Court as a whole.

DECISION: DISBARRED with FORFEITURE OFALL RETIREMENT BENEFITS MARYMALECDAN vs. PEKAS and KOLLINFacts:

Atty Pekas and Kollin substituted Atty.Bustamante as a counsels for the FangedSpouses.


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Petitioner Malecdan bought a parcel of landlocated in Baguio City from the Fanged spouses.

The money was received by Eliza Fanged anddeposited in the account of Atty. ArtemioBustamante, then counsel for the latter. Thecomplainant later found out, however, that thesaid lot was the subject of a controversy betweenthe former owners and the Fanged Spouses.

Then Kollin replaced Bustamante. He filed for apetition for rescission over the contract of sale,without returning the amount of money toMalecdan. While Malecdan was in the US, theFanged spouses, Atty Bustamante and the PCIB(bank) signed a compromised contract, andMalecdan was not made a signatory to suchcontract. They caused the transfer of P30K fromthe account of Bustamante to a separate accountfor Kollin and Pekas as attorneys fees.

Now, Malecdan files a case for disbarmentagainst Kollin and Pekas, because not only wasshe prejudiced from such withdrawal of money,but they also committed acts against the IBP incontravention/violation to the lawyers oath thatthey shall uphold the laws of the land.

Issue:

WON Kollin and Pekas should be suspended? YES

Held:

The amount of P30K which the respondents tookfor themselves as attorneys fees belonged to athird person, not their client, as admitted by themin their complaint; the owner was, in fact, anadverse party. It was the possession of themoney, its entitlement, which was in fact put inissue in the complaint for rescission of contract,and, if respondent Atty. Kollin is to be believed,prompted the filing of the complaint itself.

Atty. Kollin knew that the money did not belongto his client, Eliza Fanged, but still he knowinglywithdrew the amount of P30K to serve hisinterests.

Kollin used Pekas inexperience to gain:

By having respondent Atty. Pekas sign theManifestation of Compromise Settlement, it wasthe intention of respondent Atty. Kollin todistance himself from such pleading and claim noresponsibility or participation therein so that thesame would not be tainted by his apparentknowledge of the defect in Eliza Fangeds right toclaim the sales proceeds. In this respect,respondent Atty. Kollin and his client Eliza[F]anged have succeeded as they have secured

the release of the sales proceeds to the detrimentand prejudice of herein complainant.

Pekas knew that there was no valid compromiseagreement, as one of the parties in the case wasabsent at the time it was entered into. He knewthat no valid notice was given to the complainantsince the signatory to the notice of themanifestation of compromise agreement was acertain Veronica Buking.

It is a settled principle that the compensation of alawyer should be but a mere incident of thepractice of law, the primary purpose of which is torender public service. The practice of law is aprofession and not a money-making trade. Theprocess of imbibing ethical standards can beginwith the simple act of openness and candor indealing with clients, which would progressthereafter towards the ideal that a lawyersvocation is not synonymous with an ordinarybusiness proposition but a serious matter ofpublic interest.

DECISION: Pekas suspended for 6 months, Kollinfor 3 years.

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73555208-CAYETANO-VS-MONSOD