Cayetano vs Monsod  Judge Nilo Malanyaon assisted his daughter, Atty.

Ma. Kristina Malanyaon, during an administrative

Facts: hearing.
Christian Monsod was nominated as Chairman of  Atty. Ma. Kristina represented a party in the
COMELEC by President Corazon C. Aquino. The hearing, while her father, Judge Malanyaon, sat
Commission on Appointments confirmed his nomination. beside her.
However, Senator Cayetano challenged Monsod's  Judge Malanyaon coached and advised his
nomination, arguing that Monsod did not have the daughter during the proceedings, making
necessary qualification of being engaged in the practice statements and preparing documents.
of law for at least ten years. Issue:
 Whether Judge Nilo Malanyaon's actions
Issues: constituted conduct unbecoming of a judge.
 Whether his involvement in his daughter's legal
Whether Christian Monsod possessed the required representation violated rules against the private
qualification for the position of Chairman of COMELEC. practice of law by judges.
What constitutes the "practice of law" as a qualification. Court Ruling:
 The court found Judge Malanyaon guilty of
Court's Ruling: conduct unbecoming of a judge.
The court ruled in favor of Christian Monsod, stating that  His actions, including sitting with his daughter
he did possess the required qualification for the position. during the hearing and assisting her, indicated
The court emphasized that the practice of law extends an intention to influence the case.
beyond courtroom litigation and encompasses various  Judge Malanyaon admitted to coaching and
legal activities. Monsod's diverse legal experiences, advising his daughter during the proceedings,
including work as a lawyer-economist, manager, violating rules against judges engaging in private
negotiator, legislator, and more, met the constitutional law practice.
requirement of ten years of legal practice. The court also  The court emphasized that judges must accept
considered the modern concept of law practice and the the restrictions on their conduct and found that
liberal construction intended by the framers of the his actions breached ethical standards expected
Constitution when making this determination. of judges.

Ulep vs. The Legal Clinic Inc, Bar Matter 553, Letter of the UP Law Faculty entitled
June 17, 1993 “Restoring Integrity: A Statement by the
Faculty of the University of the Philippines
 A petition seeks to stop certain ads by the Legal College of Law on the Allegations of
Clinic related to the law profession. Plagiarism and Misrepresentation in the
 The ads promote services like secret marriages, Supreme Court.”
divorce in Guam, and annulment, offering free
books on Guam Divorce.
Facts:
 Ulep, a lawyer, finds these ads unethical and
damaging to lawyers' reputation.
 Legal Clinic argues it provides legal support  Allegations of plagiarism were made against
services, not legal practice. Justice Mariano C. Del Castillo regarding his
decision in the case of Vinuya v. Executive
Key Issues: Is Legal Clinic practicing law, and can these Secretary.
ads continue?  Attorneys Harry L. Roque, Jr. and Romel R.
Bagares, who represent the comfort women in
Ruling:
the case, raised the plagiarism allegations.
 Legal Clinic is practicing law as it offers legal
 37 members of the University of the Philippines
advice and services.
College of Law faculty, including Dean Marvic
 The ads should be stopped because they violate
M.V.F. Leonen, called for Justice Del Castillo's
legal profession standards.
resignation due to the allegations.
 Lawyers can't advertise their skills like
 The UP Law faculty treated the plagiarism
merchants, except in reputable law lists or
allegation as a truth and expressed
simple professional cards.
dissatisfaction with Justice Del Castillo's
 These ads don't qualify for exceptions and harm
explanation.
the legal profession's image, so they should be
 They also made derogatory comments about the
halted.
Supreme Court's handling of the case.
Issue:
 Whether the actions of the UP Law Faculty
Sonia Decena and Rey Decena v Judge Nilo
constitute violations of specific Canons and Rules
Malanyaon, AM No. RTJ-10-2217, April 9, 2013 in the Code of Professional Responsibility.
Court's Holding:
Facts:
  The Court issued a show cause order resolution  Rivera's actions demonstrated a lack of moral
to the UP Law Faculty members, requiring them fiber, integrity, and fitness to practice law,
to explain why they should not be disciplined as making him unfit to continue practicing.
members of the Bar.
 The case was ongoing at the time of the ruling.
Dissenting Opinions: STEPHAN BRUNET AND VIRGINIA
 Justice Sereno questioned how the UP Law ROMANILLOS BRUNET, COMPLAINANTS, VS.
Faculty's statement could affect the Court's ATTY. RONALD L. GUAREN, RESPONDENT.
ability to view the motion for reconsideration or Facts:
enforce future orders.  Complainants engaged the services of Attorney
 She also noted that the Faculty's statement Guaren to facilitate the titling of a residential lot
appeared to have a redemptive intent and aimed they acquired.
to restore the Court's integrity.  They agreed on a fee of P10,000 to be paid after
 Justice Carpio Morales criticized the Court's the delivery of the title, with an initial P1,000
response as "abrasive" and "misplaced advance.
vigilance," considering it unnecessary and  Additional payments of P6,000 were made, but
uncalled for. there was no progress in the titling process from
1997 to 2001.
 Complainants requested the return of their
money, and Attorney Guaren agreed but wanted
ADEGOKE R. PLUMPTRE,v ATTY. SOCRATES to deduct P5,000 for professional fees.
R. RIVERA  Despite having an attorney-client relationship
with complainants, Attorney Guaren made a
Facts: special appearance against them in a case
 Attorney Socrates R. Rivera faced a disbarment before the Metropolitan Circuit Trial Court.
case for absconding with money entrusted to him Issue:
and soliciting money to bribe a judge.  Whether Attorney Guaren violated the Code of
 The complainant sought Rivera's assistance in Professional Responsibility.
obtaining a work permit from the Bureau of Court's Ruling:
Immigration and paid him P10,000 as a  The practice of law is a profession where the
professional fee. duty to public service, not money, is the primary
 Rivera received additional payments from the consideration.
complainant for the processing of the work  Lawyers should prioritize duty to public service
permit. and the administration of justice over personal
 Rivera also asked for an additional P8,000, interests and financial gain.
allegedly to bribe a Las Piñas judge, but then  Attorney Guaren violated Canons 17 and 18 of
disappeared without providing any updates or the Code of Professional Responsibility by failing
services. to serve his clients with competence and
 The complainant eventually tracked down Rivera diligence.
and retrieved his passport, but Rivera refused to  He accepted payment but neglected the legal
return the P28,000 he received. matter entrusted to him, breaching his duty to
Issue: his clients.
 Whether Attorney Socrates R. Rivera should be  Lawyers are obligated to uphold the constitution,
disbarred for his actions. obey laws, and promote respect for legal
Court's Holding: processes (Canon 1).
 Attorney Socrates R. Rivera is suspended from Rationale:
the practice of law for three (3) years.  Lawyers are not merely engaged in a money-
 Rivera's actions violated multiple Canons and making venture but are bound by a duty to
Rules of the Code of Professional Responsibility. public service and the administration of justice.
 He failed to uphold the integrity and dignity of  Attorney Guaren's failure to fulfill his obligations
the legal profession, violated the trust reposed in to his clients and his contradictory actions, such
him, and neglected his client's legal matters. as making a special appearance against them,
 His solicitation of money to bribe a judge also violated the principles of competence, diligence,
disrespected the judicial system, eroding and fidelity to the client's cause.
confidence in the judiciary.  The legal profession requires lawyers to prioritize
Rationale: the interests of justice and their clients over
 Rivera's actions violated Canons 1, 7, 16, 17, and financial gain.
18 of the Code of Professional Responsibility.
 He neglected his client's case and acted
reprehensibly, including making threats and A.C. No. 12079, November 10,
refusing to return money entrusted to him. 2020 ]EDUARDO B. MANALANG,
 Soliciting money to bribe a judge undermined the
COMPLAINANT, VS. ATTY. CRISTINA
integrity of the judicial system and eroded
confidence in the judiciary.
BENOSABUENDIA, RESPONDENT.
Facts:  Ong demanded payment, but Atty. Delos Santos
 Attorney Cristina Benosa Buendia (Atty. Buendia) ignored him.
was the subject of a disbarment complaint.  Ong filed a criminal complaint against Atty. Delos
 Complainant Eduardo B. Manalang hired Atty. Santos for estafa and violation of Batas
Buendia for the nullity of his marriage. Pambansa Blg. 22 (bouncing checks law).
 They agreed on a fee, and Atty. Buendia assured  Ong also filed a disbarment complaint against
Manalang that the process would take 6 months Atty. Delos Santos with the Integrated Bar of the
to a year. Philippines (IBP).
 Manalang paid a significant sum for legal fees Issue:
and expenses.  Did Attorney Delos Santos violate the Code of
 Later, Manalang discovered that Atty. Buendia Professional Responsibility, specifically Canon 1,
had another lawyer, Atty. Neil Salazar, handling Rule 1.01, and Canon 7, Rule 7.03, by issuing a
his case in a different location. worthless check?
 Manalang was informed that his case had been Ruling:
resolved, but he was not given a copy of the  Yes, Attorney Delos Santos violated the Code of
decision. Professional Responsibility and is subject to
 When he inspected the decision, he found disciplinary action.
fabricated details about his marriage, and the Rationale:
case was never actually filed.  Lawyers are officers of the Court and have a duty
Issue: to maintain good moral character.
 Whether Atty. Buendia should be disbarred for  Attorney Delos Santos knowingly violated Batas
her misrepresentations and deceiving her client. Pambansa Blg. 22 (the bouncing checks law) by
Ruling: issuing an unfunded check, which exhibited his
 The Supreme Court has the authority to regulate indifference towards the law's pernicious effects
the legal profession and discipline its members. on public interest and order.
 Rule 138, Section 27 of the Rules of Court  His actions violated the Lawyer's Oath and the
enumerates grounds for disbarment, including Code of Professional Responsibility, specifically
deceit, malpractice, and other misconduct. Canon 1, Rule 1.01, and Canon 7, Rule 7.03.
 Lawyers are bound by the Code of Professional  Attorney Delos Santos' private dealings still
Responsibility, which includes upholding the law, required him to exhibit good faith, fairness, and
obeying the laws of the land, and promoting candor, as he was a lawyer.
respect for the legal processes.  The Court found him guilty of violating the
Rationale: Lawyer's Oath and the Code of Professional
 Lawyers must conduct themselves with integrity, Responsibility and suspended him from the
honesty, and probity. practice of law for six months, with a stern
 Atty. Buendia violated her duties to her client by warning that any similar infractions in the future
deliberately misleading and deceiving him, would be dealt with more severely.
fabricating documents, and failing to provide The decision was to be appended to Attorney Delos
updates on the case. Santos' personal record as an attorney, sent to the
 Her actions amounted to dishonesty, deceit, and Integrated Bar of the Philippines, and distributed to all
malpractice, which are grounds for disbarment. courts in the country for their information and guidance.
 She also failed to return the legal fees paid by
the client, as the money was intended for a
specific purpose, and the case was not filed. ROGELIO PASAMONTE, COMPLAINANT, VS. ATTY.
 Atty. Buendia's actions were contrary to the high LIBERATO TENEZA, RESPONDENT.
moral standards expected of lawyers, and she The case involves an administrative complaint for
was disbarred from the practice of law. disbarment filed by Rogelio Pasamonte against Atty.
Liberato Teneza. The key facts are as follows:
Facts:
BENJAMIN Q. ONG v. ATTY. WILLIAM F. DELOS 1. Rogelio Pasamonte and Atty. Liberato Teneza
SANTOS, AC. No. 10179, 2014-03-04 have known each other for over 25 years, with
Atty. Teneza having represented Rogelio in
Facts: ejectment cases and even being the godparent
 Benjamin Ong met Attorney William F. Delos of one of Rogelio's children.
Santos through a mutual acquaintance. 2. In June 2006, Atty. Teneza planned and arranged
 Ong and Atty. Delos Santos became friends, and Rogelio's wedding to Mary Grace dela Roca, even
Atty. Delos Santos asked Ong to encash his though Rogelio was already married to someone
postdated check for him, assuring Ong that the else. Atty. Teneza assured Rogelio that their
check would be funded. marriage would not be registered with the Local
 Ong gave Atty. Delos Santos ₱100,000.00 in Civil Registry.
exchange for the postdated check. 3. Mary Grace later filed a case against Rogelio for
 However, the check bounced because the bigamy and violation of Republic Act No. 9262
account was closed. (Anti-Violence Against Women and Their Children
Act). In the course of this case, it was revealed
 that Atty. Teneza himself was involved in a  Teoxon promised Tumbaga financial support and
bigamous marriage. He had married Victoria claimed his marriage to another woman was
Reyes on April 18, 1979, and then married invalid.
Charina dela Roca on July 3, 1993.  Tumbaga moved in with Teoxon, became
4. Rogelio also learned that Atty. Teneza had been a pregnant, and they had a child together.
witness in the marriages of other individuals and  Teoxon allegedly failed to provide the promised
accused him of meddling with the processes of financial support, leading Tumbaga to file the
the Local Civil Registry. Additionally, Atty. Teneza complaint.
reneged on his promise not to register Rogelio's  Teoxon denied the allegations, accusing Tumbaga
marriage with Mary Grace. of extortion and disputing paternity.
Issue:
Issue: The primary issue in this case is whether Atty.  Should Atty. Manuel P. Teoxon be disciplined,
Teneza should be disbarred from the practice of law due particularly for gross immorality, based on
to his alleged immoral acts, specifically his involvement Tumbaga's complaint?
in a bigamous marriage and his complicity in other Court Ruling:
bigamous marriages.  Teoxon was found guilty of gross immorality.
 The court determined that Teoxon's actions,
Ruling: The court ruled in favor of disbarment for Atty. including the extramarital relationship, false
Teneza. The court found him guilty of gross immorality in promises of financial support, and attempts to
violation of the Code of Professional Responsibility. The distort the truth, constituted grossly immoral
key points in the court's ruling are as follows: conduct.
1. Atty. Teneza contracted a second marriage while  The Rules of Court authorize the suspension or
his first marriage was still legally valid. This act disbarment of lawyers for gross immorality.
alone rendered him unfit to continue as a  The Integrated Bar of the Philippines (IBP)
member of the Bar. The court emphasized that initially recommended a two-year suspension,
lawyers should be aware of and follow the law, which was increased to three years by the IBP
especially when it comes to issues as Board of Governors.
fundamental as marriage.  The court upheld the three-year suspension from
2. Atty. Teneza was complicit in two bigamous practicing law for Teoxon.
marriages, including Rogelio's. He knew that  A stern warning was issued against Teoxon for
Rogelio had a subsisting marriage when he potential future misconduct.
assisted in Rogelio's bigamous marriage.
Furthermore, he attended the weddings of other
individuals involved in bigamous marriages and
claimed that he did so to be a witness in case
something went wrong, which the court found to
be an inadequate excuse.
3. The court stressed that lawyers must uphold the
highest degree of morality, both in their
professional and private lives, to maintain the
integrity of the legal profession.
4. The court cited previous cases where lawyers
were disbarred for engaging in bigamous
marriages, as such conduct constitutes gross
immorality.
In summary, Atty. Teneza was disbarred from the
practice of law due to his involvement in a bigamous
marriage and his complicity in other similar marriages,
which the court deemed as grossly immoral conduct.

A.C. No. 5573

GIZALE O. TUMBAGA, Complainant vs. ATTY.
MANUEL P. TEOXON, Respondent

Facts:
 Gizale O. Tumbaga filed an administrative
complaint against Atty. Manuel P. Teoxon.
 Tumbaga accused Teoxon of gross immorality,
deceitful and fraudulent conduct, and gross
misconduct.
 Tumbaga and Teoxon had a romantic relationship,
starting when Teoxon was the City Legal Officer
of Naga City.