Duties to the society


MONTECILLO v GICA
G.R. No. L-36800. October 21, 1974
ESGUERRA, J.
FACTS:

Montecillo was accused by Gica of slander. Atty. del Mar represented Montecillo and he successfully defended Monteceillo in the lower court. The Court of Appeals reversed the same. Atty. Del Mar then filed a motion for reconsideration where he made a veiled threat against the Court of Appeals judges intimating that he thinks the CA justices “knowingly rendered an unjust decision” and “judgment has been rendered through negligence” and that the CA allowed itself to be deceived.

But the CA did not reverse its judgment. Del Mar then filed a civil case against the three justices of the CAthe CA suspended Atty. Del Mar from practice.

Del Mar asked the SC to reverse his suspension as well as the CA decision as to the Montecillo case, but SC denied both. Del Mar also intimated that even the Supreme Court is part among “the corrupt, the grafters and those allegedly committing injustice”.

Del Mar even filed a civil case against some Supreme Court justices but the judge who handled the case dismissed the same.

ISSUE: Whether Atty. Del Mar should be held liable.

HELD: Yes. It is the duty of the lawyer to maintain towards the courts a respectful attitude. As an officer of the court, it is his duty to uphold the dignity and authority of the court to which he owes fidelity, according to the oath he has taken.

Del Mar was then suspended indefinitely.

ORONCE v CA
G.R. No. 125766. October 19, 1998
ROMERO, J.

Facts: During a dispute over land, Flaminiano illegally took possession of the property in litigation using abusive methods. She was aided by her husband, a lawyer. The illegal entry took place while the case was pending in the CA & while a writ of preliminary injunction was in force.

ISSUE: Whether  Atty. Flaminiano should be held liable.

Held: Atty. Flaminiano’s acts of entering the property without the consent of its occupants & in contravention of the existing writ or preliminary injunction & making utterances showing disrespect for the law & this Court, are unbecoming of a member of the Bar. Although he says that they “peacefully” took over the property, such “peaceful” take-over cannot justify defiance of the writ of preliminary injunction that he knew was still in force. Through his acts, he has flouted his duties as a member of the legal profession. Under the Code of Professional Responsibility, he is prohibited from counseling or abetting “activities aimed at defiance of the law or at lessening confidence in the legal system.”

DE YSASI v NLRC
G.R. No. 104599. March 11, 1994
REGALADO, J.

FACTS:

Atty. De Ysasi and De Ysasi III are father and sons respectively. The father owns a hacienda in Negros Occidental. Son is employed in the hacienda as the farm administrator. Son III underwent surgery and so he missed work. He was confined and while he’s nursing from his infections he was terminated, without due process, by his father. Son filed against his father for illegal dismissal before the NLRC. His father invoked that his son actually abandoned his work.

ISSUE:
Whether or not De Ysasi III abandoned his work.
Whether they failed to settle without resorting to the courts.

HELD: No. His absence from work does not constitute abandonment. To constitute abandonment, there must be a.) failure to report for work or absence without valid or justifiable reason, and b.) a clear intention to sever the employer-employee relationship, with the second element as the more determinative factor and being manifested by some overt acts. No such intent was proven in this case.

Yes. Once again, we reiterate that the useful function of a lawyer is not only to conduct litigation but to avoid it whenever possible by advising settlement or withholding suit. Their relationship allows them to settle the case even without resorting to the court.

PAJARES v ABAD SANTOS
G.R. NO. L-29543. November 29, 1969
TEEHANKEE, J.

FACTS:
Udharam Bazar & Co. sued Gloria Pajares for recovery of a certain sum of money. The lawsuit was eventually assigned to the sala of the respondent Judge Abad Santos.
In its complaint the Udharam Bazar & Co. averred, that pajares received the ordered good but never paid.
Instead of answering the complaint against her, Pajares, moved for a bill of particulars to require Udharam Bazar & Co. to itemize the kinds of goods which she supposedly purchased from the said company. Pajares alleged that the judge acted in grave abuse of discretion and sent petition in CFI up to SC.

ISSUE:
Whether counsel for petitioner failed in his duty to encourage amicable settlement or a confession of judgment to accord respect to the other party’s claim, saving his client additional expenses and help prevent the clogging of court dockets.

RULING:
Yes. The appeal is frivolous and a plain trick to delay payment and prolong litigation unnecessarily. Such attitude deserves condemnation, wasting as it does, the time that the courts could well devote to meritorious cases.
This simple collection case has needlessly clogged the court dockets for over seven years. Had appellant been but prudently advised by her counsel to confess judgment and ask from her creditor the reasonable time she needed to discharge her lawful indebtedness, the expenses of litigation that she has incurred by PEOPLE v ROSQUETA
G.R. No. L-36138. January 31, 1974
FERNANDO, J.

FACTS:
Rosqueta Jr and two others were convicted of a crime. They appeal their conviction until it reached the Supreme Court. Their lawyer (counsel de parte) Atty. Estacio, failed to file their Brief. SC suspended him after failure to submit his explanation why he should not be disciplined for failure to file said Brief. He filed a Motion for Reconsideration and said that he did prepare an explanation the same being left with Rosqueta Sr (father of accused) for the latter to mail it, however the latter’s house burned down together with it and he only knew it when filing MR.
Atty. Estacio also explained that his clients are withdrawing their appeal by reason of their failure to raise the needed fund for the appeal.
ISSUE: Whether Atty. Estacio’s suspension should continue.

HELD: No. His liability is mitigated. But the Supreme Court noted that Atty. Estacio has been irresponsible, has been negligent and inattentive to his duty to his clients. Difficulty in the amount necessary to pursue the appeal,  does not necessarily conclude his connection with the case.  He should be aware that in the pursuance of the duty owed this Court as well as to a client, he cannot be too casual and unconcerned about the filing of pleadings. It is not enough that he prepares them; he must see to it that they are duly mailed. Such inattention as shown in this case is inexcusable.



De Roy v CA
G.R. No. 80718. January 29, 1988
Cortes, J:

FACTS
The firewall of a burned out building owned by Felisa De Roy collapsed and destroyed the tailoring shop occupied by the family of Bernal resulting in injuries and to the death of Bernal’s daughter. He was found guilty of gross negligence.
On the last day of filing a motion for reconsideration, De Roy’s counsel filed a motion for extension. It was denied by the CA pursuant to the case of Habaluyas vs Japzon, the fifteen-day period for appealing or for filing a motion for reconsideration cannot be extended.
De Roy’s counsel however argued that the Habaluyas case should not be applicable because said ruling was never published in the Official Gazette.
ISSUE: Whether or not Supreme Court decisions must be published in the Official Gazette before they can be binding.
HELD: No. There is no law requiring the publication of Supreme Court decision in the Official Gazette before they can be binding and as a condition to their becoming effective. It is bounden duty of counsel as lawyer in active law practice to keep abreast of decisions of the Supreme Court particularly where issues have been clarified, consistently reiterated and published in the advance reports of Supreme Court decisions and in such publications as the SCRA and law journals.

Jose v CA
G.R. No. L-38581. March 31, 1976
Munoz-Palma, J.

FACTS

Jose was caught possessing several firearms and explosives. He was prosecuted for illegally possessing said firearms and explosives. he said that he is authorized to carry the explosives and made a reservation to present his evidence at a later time. Trial Court convicted him for illegal possession of hand grenade.

The Solicitor General opposed the MFR/New Trial as it stated that the evidence sought to be presented by Jose does not fall under “newly discovered evidence”; that his permit to possess a hand grenade was supposed to be known to Jose at the time of the trial and not discovered thereafter.
Jose confirmed he is an undercover agent for the Philippine Constabulary; that being such, he was authorized to carry firearms and explosives; that the reason why he did not disclose the same immediately was because of his fear for reprisals considering that he resides in “Huklandia”

ISSUE: Whether there can be New tiral
HELD: Yes. This is a situation where a rigid application of rules of procedure must bow to the overriding goal of courts of justice — to render justice where justice is due  to secure to every individual all possible legal means to prove his innocence of a crime of which he is charged. That a prosecuting officer, as the representative of a sovereignty whose obligation and interest in a criminal prosecution is not that it shall win a case but that justice shall be done, has the solemn responsibility to assure the public that while guilt shall not escape, innocence shall not suffer.

People v Pineda
G.R. No. L-26222. July 21, 1967
Sanches, J.

FACTS:
Defendants are charged with five cases of murder. However, two of the defendants moved to consolidate the five criminal cases into one and disregard the other four. Their plea is that said cases arose out of the same incident and motivated by one impulse. The Judge approved to unify all five (5) cases.

ISSUE: Whether the fiscal should insist the five criminal cases.

RULING
NO. A prosecuting attorney, by the nature of his office, is under no compulsion to file a particular criminal information where he is not convinced that he has evidence to prop up the averments thereof, or that the evidence at hand points to a different conclusion.

People v Madera
G.R. No. L-35133. May 31, 1974
Fernandez, J.

FACTS:
While Bana was sleeping in his house, he was shot by Madera. Behind Madera were Marianito and Generoso. Elino Bana died before he could be brought to the hospital but he made a dying statement wherein he positively identified Madera as his shooter. Two of Bana’s sons who were at the house when the shooting happened identified Madera as the shooter as well as the two behind him. All of them was convicted of murder.

ISSUE: Whether the Solicitor General can recommend acquittel of Marianito and Generoso        

HELD: YES. insofar as Marianito and Generoso is concerned – Madera’s guilt is proven beyond reasonable doubt. But Marianito’s and Generoso’s guilt were not established. This is good a time as any to emphasize upon those in charge of the prosecution of criminal cases that the prosecutor's finest hour is not when he wins a case with the conviction of the accused. His finest hour is still when, overcoming the advocate's natural obsession for victory, he stands up before the Court and pleads not for the conviction of the accused but for his acquittal.

Tan v Gallardo
G.R. No. L-41213-14. October 5, 1976
Antonio, J.

FACTS
The petitioners were convicted of double murder case. Judge Gallardo was accused of partiality after increasing the penalty to double life sentences, after meeting with Mayor Larazzabal, who is the uncle of the victims. The Solicitor General moved for new trial but the private prosecutors disagreed.

ISSUES
Whether the Private prosecutors can intervene.

HELD
No. Therefore, although the private prosecutors may be permitted to intervene, they are not in control of the case, and their interests are subordinate to those of the People of the Philippines represented by the fiscal.

People v Sendaydiego
G.R. Nos. L-33252-54. January 20, 1978
Aquino, J.

FACTS:
The acting provincial commander, who filed the complaints, manifested to the trial court that he had authorized Atty. Millora to act as private prosecutor. The city fiscal, assistant provincial fiscal, also authorized Atty. Millora and Atty. Ubiztondo to conduct examinations, subject to their control and supervision.


Issue:  Whether the Defense counsel ask for the inhibition of the private prosecutors.

Held: No. Private prosecutors may appear in criminal cases “under the direction and control of the fiscal” and that “the provincial fiscal shall represent the province in any court.” The fiscals were present in all the appearance of the private prosecutor and there was proper compliance.


Misamin v San Juan
A.C. No. 1418. August 31, 1976
Fernando, J.

Facts: respondent admits appearing as counsel for the New Cesar’s Bakery in the proceeding for violations of minimum wage law before the NLRC while he held office as captain in the Manila Metropolitan Police. Respondent contends that the law did not prohibit him from such isolated exercise of his profession. He contends that his appearance as counsel while holding a government position is not among the grounds provided by the Rules of Court for the suspension or removal of attorneys.

Issue: Whether respondent should be held administratively liable.

Held: No. There can only be suspicion that he used his public office, despite being a public trust, and not his legal knowledge, it shall not pass being unnoticed.  Respondent, in his future actuations as a member of the bar, should refrain from laying himself open to such doubts and misgivings as to his fitness not only for the position occupied by him but also for membership in the bar. He is not worthy of membership in an honorable profession who does not even take care that his honor remains unsullied.


PCGG v Sandiganbayan
G.R. Nos. 151809-12.  April 12, 2005        
Puno, J.

Former Solicitor General Mendoza, who has currently resumed the private practice of law, was sought to be disqualified from representing the Lucio Tan group, in the 1987 case involving General Bank and Trust Company (GENBANK) as one of those properties being alleged to be ill –gotten wealth acquired during the Marcos Regime. PCGG averred that there exists an adverse interest on Mendoza since he was the one who filed a petition praying for assistance and supervision of the court in the liquidation of GENBANK when he was still a Solicitor General, which bank was subsequently owned by the Lucio Tan group when it submitted the winning bid.

Issue: Whether there is conflict of interest

Ruling:
No, Rule 6.03 of the CPR is inapplicable in the case. the word “intervene” is applicable to both adverse interest conflicts and congruent interest conflicts, it has been found that neither of these conflicts exists in the liquidation case and the sequestration case. Matter as any discrete, isolatable act as well as identifiable transaction or conduct involving a particular situation and specific party, and not merely an act of drafting, enforcing or interpreting government or agency procedures, regulations or laws, or briefing abstract principles of law.

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