1. Rivera v.

Angeles
A.C. No. 2519, August 29, 2000
Ynares-Santiago, J.

Facts:

Respondent Atty. Sergio Angeles was the counsel of record of petitioners Teodoro Rivera, et. al. in two
civil cases filed in the CFI of Rizal. In said cases, after petitioners received a favorable decision from the
CFI and sustained by the CA and SC, an alias writ of execution was issued.

In the first week of January of 1983, the petitioners received from the CFI a sheriff’s return stating that
no leviable property can be found in the premises of therein defendants. However, on January 13, 1983,
petitioners learned that Rodolfo Silva, one of the defendants, had already given Atty. Angeles a down
payment of P42,999. Atty. Angeles allegedly never informed petitioners thereof. A letter of demand was
thereafter sent to Atty. Angeles but petitioners did not receive a reply.

Thus, petitioners filed the instant case for the disbarment of Atty. Angeles on the grounds of deceit and
malpractice. In his Comment, Atty. Angeles argued that he had the right to retain the said amount of
P42,999 and to apply the same to professional fees due him under a subsequent agreement embodied
in a Deed of Assignment. Petitioners deny that they assigned their rights to Atty. Angeles.

Issue: Whether or not Atty. Sergio’s actions are ethical.

Held: No. The Court adopted the report of the Integrated Bar of the Philippines finding Atty. Angeles
guilty of violating the Code of Professional Responsibility specifically Rule 1.01, Canon 16 and Rule 16.01
thereof and its recommendation of his suspension from the practice of law.

Respondent’s act of deceit and malpractice indubitably demonstrated his failure to live up to his sworn
duties as a lawyer. The Court has repeatedly stressed the importance of integrity and good moral
character as part of a lawyer’s equipment in the practice of his profession. For it cannot be denied that
the respect of litigants for the profession is inexorably diminished whenever a member of the Bar
betrays their trust and confidence.

While the Court is not oblivious of the right of a lawyer to be paid for the legal services he has extended
to his client, such right should not be exercised whimsically by appropriating to himself the money
intended for his clients. There should never be an instance where the victor in litigation loses everything
he won to the fees of his own lawyer.

2. Ducat Jr. v Villalon Jr.

Facts:

Atty. Arsenio Villalon Jr. was the lawyer of the family of petitioner Jose Ducat Jr. In October 1991, Atty.
Villalon asked the father of petitioner, Jose Ducat Sr., for the title of the land subject of this case on the
pretense that it was necessary to verify the measurements of said property. In November 1991,
however, petitioner and his family were surprised when several people entered the said property for the
purpose of establishing a piggery for one Andres Canares. When petitioner complained to the barangay,
Canares did not appear before it and continued with constructing the piggery in the presence of armed
men.

Petitioner then filed a complaint for ejectment against Canares. In his Reply, Canares asserted that the
subject property has already been sold by petitioner to him for P450,000. Petitioner discovered that
respondent Villalon claimed that his father gave the subject property to Villalon.

Petitioner thus filed this complaint for disbarment against Atty. Villalon Jr. for deceit and gross
misconduct in violation of the lawyer's oath. In his Comment, Atty. Villalon Jr. asserted that the property
was given voluntarily by Ducat, Sr. to him out of close intimacy and for past legal services rendered.
Thereafter, he allowed the subject property to be used by Canares to start a piggery business without
any monetary consideration. A Deed of Sale of Parcel of Land was signed by Ducat, Sr. to evidence that
he has conveyed the subject property to respondent Villalon with the name of respondent Canares
included therein as protection because of the improvements to be introduced in the subject property.
However, since the title was in the name of Jose Ducat Jr., Jose Ducat Sr. undertook to transfer the title
directly in the name of Canares.

Petitioner denies that he signed the Deed of Sale covering the subject property; nor did he appear
before the notary public who notarized the same.

Issue: Whether or not Atty. Villalon’s actions warrant disciplinary sanction.

Held: Yes. Atty. Villalon insists that the subject property was transferred to him orally by Ducat Sr. with
full knowledge that the property is owned by petitioner. It is basic law, however, that conveyance or
transfer of any titled real property must be in writing, signed by the registered owner or at least by his
attorney-in-fact by virtue of a proper special power of attorney and duly notarized. Respondent Villalon,
as a lawyer, is presumed to know, or ought to know, this process. Worse, Atty. Villalon consented to the
forgeries he contends were committed by Jose Ducat Sr. and the execution of a simulated deed of sale.
In all, Atty. Villalon's acts herein complained of constitute gross misconduct.

The ethics of the legal profession rightly enjoin lawyers to act with the highest standards of truthfulness,
fair play and nobility in the course of his practice of law. A lawyer may be disciplined or suspended for
any misconduct, whether in his professional or private capacity, which shows him to be wanting in moral
character, in honesty, in probity and good demeanor, thus rendering unworthy to continue as an officer
of the court. Canon 7 of the Code of Professional Responsibility mandates that "a lawyer shall at all
times uphold the integrity and dignity of the legal profession." The trust and confidence necessarily
reposed by clients require in the lawyer a high standard and appreciation of his duty to them. To this
end, nothing should be done by any member of the legal fraternity which might tend to lessen in any
degree the confidence of the public in the fidelity, honesty, and integrity of the profession.

Thus, Atty. Villalon was suspended from the practice of law for one year.

3. Tan v. Sabandal
B.M. No. 44, November 29, 1983
Melencio-Herrera, J.

Facts:
Respondent Nicolas El. Sabandal, a successful bar examinee in 1978, filed a petition to be admitted to
the Philippine Bar and to be allowed to sign the Roll of Attorneys. Petitioner Eufrosina Tan is one of the
oppositors thereto charging Sabandal with, among others, the illegal practice of law for accepting clients
and for his appearances as a lawyer even if he has not yet been admitted to the Bar.

She substantiated her charge with a photostatic copies of transcripts and stenographic notes of CAR
Case No. 347 before the Court of Agrarian Relations wherein respondent manifested "Atty. Nicolas
Sabandal, appearing for the defendants, Your Honor" and alleged that the counsel of record was sick.

Respondent countered that the charges against him were baseless. Particularly, he avers that he was
merely assisting his parents-in-law, Daniel Iman and Rosa Carreon, in CAR cases Nos. 347 and 326 as
allowed under Sec. 14(k) of PD 946, and that it was the stenographer who had inadvertently entered his
name as "Atty. Sabandal" in those cases. He further posits that the Code of Ethics does not apply to him
but only to members of the Bar.

Issue: Whether or not Sabandal is fit to be admitted to the Bar.

Held: No. The Court found that Sabandal engaged in the unauthorized practice of law. It was clear from
the proceedings in CAR Case No. 347 that he specifically manifested “Atty. Nicolas Sabandal, appearing
for the defendants, Your Honor,” calling himself "attorney" knowing full well that he was not yet
admitted to the Bar. He cannot shift the blame on the stenographer, for he could have easily asked for
rectification. It must be noted that in the court of a municipality, even non-lawyers may appear (Sec. 34,
Rule 138, Rules of Court). However, respondent did not so manifest his appearance. What he did was to
hold himself out as a lawyer.

Furthermore, respondent's additional defense that the code of professional ethics does not apply to him
as he is not yet a member of the Bar proves him unfit to be admitted to the profession that exacts the
highest ethical conduct of all its members, and good moral character even for applicants for admission
to the Bar. He could at least have shown his fitness for admission by showing adherence to and
observance of the standards of conduct required by all who aspire to profess the law.

4. In Re: Investigation of Angel J. Parazo for alleged leakage of questions in some subjects in the 1948
Bar Examinations
G.R. No. 120348, December 3, 1948
Montemayor, J.

Facts:

Angel J. Parazo, reporter of the Star Reporter, wrote a story on an alleged leakage in some subjects in
the 1948 Bar Examinations. The Supreme Court conducted an investigation and called Prazo for
questioning. Therein he asserted that he wrote up the story and had it published in good faith and in the
spirit of public service and that he knew the persons who gave him the information which formed the
basis of his publication. The SC repeatedly appealed to Prazo to reveal the names of his informants so
that it may be in a position to start and conduct the necessary investigation in order to verify their
charge and complaint and take action against the party or parties responsible for the alleged irregularity
and anomaly. Parazo, however, consistently refused to make the revelation purportedly because the
information was given to him in confidence and his informants did not wish to have their identities
revealed. This resulted to the SC issuing a resolution requiring Parazo to reveal the identity of the
informants or be cited in contempt.

At the request of Parazo’s counsel, a hearing was conducted wherein he anchored his refusal to reveal
the identities of his informants on the benefits of Section 1 of Republic Act No. 53 which provides that
the publisher, editor or duly accredited reporter of any newspaper, magazine or periodical of general
circulation cannot be compelled to reveal the source of any news-report or information appearing in
said publication which was related in confidence to such publisher, editor or reporter, unless the court
or a House or committee of Congress finds that such revelation is demanded by the interest of the state.
Counsel contends that the phrase "interest of the state" found in the exception of said provision refers
only to the security of the state, that is to say — that only when national security or public safety is
involved.

Issue: Whether or not the Bar Examinations anomaly come within the meaning of “interest of the state”
as to allow compulsion by the court of revealing the source of news information.

Held:

Yes. The Court found from the deliberations of R.A. No. 53 that the phrase "interest of the state" was an
amendment introduced by Senator Sotto of the phrase “public interest.” The said amendment was
approved without much discussion. What may account for the readiness or lack of objection on the part
of the Senate is that, as shown from the records, the phrase "public interest" was used interchangeably
by some Senators with the phrase "interest of the state."

The phrase, therefore, cannot be confined and limited to the "security of the state" or to "public safety"
alone. Furthermore, these synonymous phrases are not uncommon terms as these are used in the
Constitution and various laws. It can thus be presumed that the legislators were familiar with them and
if they had meant to limit the exception to the immunity of newspapermen only to cases where the
"security of the state," i. e., "national security" is involved, it could easily and readily have used such
phrase. Since it did not do so, there is valid reason to believe that that was not in the mind and intent of
the legislators, and that, in using the phrase "interest of the state," it extended the scope and the limits
of the exception when a newspaperman or reporter may be compelled to reveal the sources of his
information.

The phrase "interest of the state" is quite broad and extensive. It is more general and broader than
"security of the state" although not as broad and comprehensive as "public interest." The phrase
"interest of the state" even under a conservative interpretation, may and does include cases and
matters of national importance in which the whole state and nation, not only a branch or
instrumentality thereof is interested or would be affected.

The present case falls and may be included within the meaning of the phrase "interest of the state,"
involving as it does, not only the interests of students and graduates of the law schools and colleges, and
of the entire legal profession of this country as well as the good name and reputation of the members of
the Committee of Bar Examiners, including the employees of the Supreme Court having charge of and
connection with said examinations, but also the highest Tribunal of the land itself which represents one
of the three coordinate and independent branches or departments of the Philippine Government.

Thus, Parazo was cited in contempt and ordered his confinement for one month is jail.
5. Pangan v Ramos
A.C. No. 1053, August 31, 1981
De Castro, J.

Facts:

On November 29, 1971, Santa Pangan filed before the SC a verified complaint charging respondent Atty.
Dionisio Ramos with gross immorality, alleging that the latter misrepresented himself as still "single"
when he started courting complainant, proposed marriage to her and finally succeeded in marrying her
even with full consciousness that his first marriage to his first wife was still valid and subsisting. Pangan
also filed a complaint for bigamy in the CFI of Manila.

Atty. Ramos denied the charges and countered that Pangan knew at the outset of his married status but
she still wished to carry on a love affair with him; that, to cover up her pregnancy, he was threatened
and forced into marriage by her brothers who are allegedly notorious police characters; and that the
disbarment proceedings were initiated because he refused to elope with her and abandon his wife.

Meanwhile, the CFI of Manila acquitted Atty. Ramos of the charges of bigamy on grounds of insufficiency
of evidence. Atty. Ramos then submits that having been acquitted of the charge of bigamy, the
immorality charges filed against him in this disbarment case should be dismissed.

Issue: Whether or not Atty. Ramos is guilty of gross immorality.

Held: Yes. The Court found credence in Pangan’s allegations. Atty. Ramos frankly admitted having carnal
relations with Pangan for several times. He claimed that he was threatened and forced to marry Pangan,
but in the same breath, he admitted having carnal affair with her after the celebration of the marriage.
Worse still, he misrepresented his civil status as "single", courted Pangan, proposed marriage to her
despite knowing his legal impediments to marry, won her confidence and actually married her. His
motives were clearly and grossly immoral which warrants proper disciplinary action.

Moreover, in Villasanta v. Peralta, the Court held that the act of contracting a second marriage or even
making love to another woman while his first wife is still alive and their marriage still valid and existing,
is contrary to honesty, justice, decency and morality. It is a mockery of marriage which is a sacred
institution demanding respect and dignity.

The contention of Atty. Ramos that he should be acquitted from the disbarment case on account of his
acquittal in the criminal charge of bigamy is without merit. The standards of legal profession are not
satisfied by conduct which merely enables one to escape the penalties of the criminal law.

6. Narido v. Linsangan
A.C. No. 944, July 25, 1974
Fernando, J.

Facts:

Flora Narido filed this administrative complaint against respondent Atty. James S. Linsangan asserting
that he violated the attorney's oath by submitting the perjured affidavit of one Milagros M. Vergel de
Dios.
Atty. Linsangan thereafter filed an administrative complaint against Atty. Rufino Risma wherein he
alleged that, by virtue of the latter’s financial interest in the Award, and in order to accomplish a short
cut in winning a case, Atty. Risma instigated his client Narido, to file a false and malicious complaint
against him.

Issue: Whether or not the actions of Atty. Linsangan and Atty. Risma warrant disciplinary sanction.

Held: No. As to the charge against Atty. Linsangan, it was found that there was nothing improper in the
submission of the affidavit complained of, its alleged falsity not being proven. As to the charge against
Atty. Risma, the Court found that Narido, Atty. Risma’s client, is a destitute woman who needed every
centavo of the award. It is thus more in keeping with Christian precepts to say that it must have been
the plight of Narido, rather than his alleged financial interest, that compelled Atty. Risma to advise his
client to file the case against Atty. Linsangan. There being no direct evidence to show bad faith on the
part of Atty. Risma, the benefit of the doubt should be resolved in his favor.

The Court nevertheless advised the two respondents to heed these words from Justice Laurel,
announced in Javier v. Cornejo: "It should be observed, in this connection, that mutual bickerings and
unjustifiable recriminations, between brother attorneys detract from the dignity of the legal profession
and will not receive any sympathy from this court."

7. Laput v. Remotigue
A.C. No. 219, September 29, 1962
Labrador, J.

Facts:

Atty. Casiano Laput was retained by Nieves Barrera to handle the special proceeding for the
administration of the estate of Macario Barrera. Atty. Laput contemplated on closing the administration
proceedings and prepared two pleadings therefor. However, Mrs. Barrera refused countersign the same
and advised Atty. Laput not to file them. Atty. Laput later found out that Atty. Fortunato Patalinghug and
Atty. Francisco Remotigue have entered their appearance as counsel in the said case.

Atty. Laput filed the instant complaint charging Atty. Patalinghug and Atty. Remotigue of unprofessional
and unethical conduct in soliciting cases and intriguing against a brother lawyer, and praying that
respondents be dealt with accordingly.

Issue: Whether or not respondents’ conduct are unethical.

Held: YES. It was found that even before Atty. Patalinghug entered his appearance, the Mrs. Barrera has
already filed with the court a pleading discharging the petitioner. If she did not furnish Atty. Laput with a
copy of the said pleading, it was not the fault of Atty. Patalinghug but that of Mrs. Barrera. It appears
that the reason why Mrs. Barrera dismissed petitioner as her lawyer was that she did not trust him any
longer, for she found out that: dividend checks which should have been sent to her were instead sent to
petitioner; and withdrawals from PNB and BPI have been made by petitioner without her prior
authority.

Moreover, petitioner's voluntary withdrawal as counsel for Mrs. Barrera after Atty. Patalinghug had
entered his appearance, and his filing almost simultaneously of a motion for the payment of his
attorney's fees, amounted to an acquiescence to the appearance of Atty. Patalinghug. He is therefore
estopped from complaining that the appearance of Atty. Patalinghug was unprofessional. Much less can
Atty. Remotigue be held guilty of unprofessional conduct inasmuch as he entered his appearance only
after Mrs. Barrera had dispensed with petitioner's professional services and after petitioner had
voluntarily withdrawn his appearance.

8. Camacho v. Pangulayan
A.C. No. 4807, March 22, 2000
Vitug, J.

Facts:

Petitioner Atty. Manuel N. Camacho was the hired counsel of some expelled students of AMA Computer
College (AMACC) in an action for the issuance of a writ of preliminary mandatory injunction pending
with the CFI of Quezon City. Atty. Camacho alleges that respondents (lawyers comprising the Pangulayan
and Associates Law Offices) counsel for the defendants, procured and effected on separate occasions,
without his knowledge, compromise agreements with four of his clients which, in effect, required them
to waive all kinds of claims they might have had against AMACC.

Complainant averred that such an act of respondents was unbecoming of any member of the legal
profession warranting either disbarment or suspension from the practice of law.

Issue: Whether or not the petitioner’s contentions are meritorious.

Held: Yes. When the compromise agreements were formalized, complainant was by then already the
retained counsel for plaintiff students in the civil case. Respondent Pangulayan had full knowledge of
this fact. Although aware that the students were represented by counsel, respondent proceeded,
nonetheless, to negotiate with them and their parents without at the very least communicating the
matter to their lawyer.

This failure of respondent whether by design or because of oversight, is an inexcusable violation of the
canons of professional ethics, particularly Canon 9 which requires that a lawyer should not in any way
communicate upon the subject of controversy with a party represented by counsel, much less should he
undertake to negotiate or compromise the matter with him, but should only deal with his counsel. It is
incumbent upon the lawyer most particularly to avoid everything that may tend to mislead a party not
represented by counsel and he should not undertake to advise him as to law.

As such, Atty. Pangulayan was suspended from the practice of law for three months.

9. W. W. Robinson v. Villafuerte
G.R. No. L-5346. January 3, 1911.
Torres, J.

Facts:

W. W. Robinson filed a suit against Marcelino Villafuerte for the collection of various sums allegedly
owed by the latter, the payment of which is secured by a mortgage on the real properties set out in the
two notarial documents evidencing the debt and inscribed in the property registry of the Province of
Tayabas. The subject loans and encumbrances were allegedly incurred by Villafuerte through his
attorney-in-fact, Vicente Concepcion, who was fully empowered therefor through a power of attorney.
Villafuerte denies liability, as he asserts that he never issued a Power of Attorney for any purpose to
Concepcion.

During the hearing of the case, Jose Moreno Lacalle, a law clerk and employee of petitioner’s attorneys
in the suit, was permitted to address questions to some of the witnesses, notwithstanding the presence
of petitioner’s counsel, Atty. Agustin Alvarez. It is alleged that the evidence obtained in the proceeding
wherein Lacalle intervened should be stricken out as they were made by a person who was neither a
party to the suit nor counsel for the plaintiff.

Issue: Whether or not the evidence obtained during Lacalle’s intervention should be stricken out.

Held: No.

As Lacalle did not have the capacity and qualifications of a lawyer admitted under oath to practice his
profession before the courts, on objection being made to his being present at the hearing of the case,
the judge should have sustained such objection and should have excluded Lacalle and not permitted him
to address questions to the plaintiff's witnesses.

Notwithstanding this, the acts performed in the course of some of the proceedings under his direction
are not subject to annulment, as no positive detriment was caused to the defendant, although such
intervention is in no manner permitted by the law of procedure.

Even though the questions addressed by a Lacalle to the witnesses of petitioner whom he endeavored
to represent should be considered as stricken out, no reason, based upon any positive prohibition of the
law is submitted to authorize the striking out of the answers given by the witnesses interrogated, even
though such answers may have been provoked by questions by a person not authorized by law, and
there is much less reason for rejecting the cross-questions put to the same witnesses by the attorney for
the other side.

Furthermore, although the presentation of the documents which support the claims of the plaintiff party
be deemed to be improper, on account of their having been made by a person who had not the
qualifications of a practicing attorney it is nevertheless true that their presentation was authorized by
Atty. Alvarez and the documents exhibited continued to be united to the record and were not stricken
out therefrom on motion by the other side, but, on the contrary, the attorney for the defendant or his
counsel discussed the authenticity and validity of the said documents, made allegations against the
same and concluded by asking that these documents, and also the inscription of those designated under
letters A and B, be declared null and void.

10. Tan Tek Beng v. David

Facts:

Tan Tek Beng and Atty. Timoteo A. David executed a written agreement which provides that Tan Tek
Beng, a non-lawyer, is to receive one half of the fees received by Atty. David from the clients supplied by
Tan Tek Beng. Furthermore, Atty. David bound himself not to deal directly with the clients.

For allegedly not living up to the agreement, Tan Tek Beng in 1973 denounced David to the Court.
Issue: Whether or not disciplinary action should be taken against Atty. David.

Held: Yes. The Court held that the agreement between Tan Tek Beng and Atty. David is void as it was
tantamount to soliciting cases at law for the purpose of gain through paid agents or brokers, designated
as malpractice under Section 27, Rule 138 of the RoC.

While malpractice ordinarily refers to any malfeasance or dereliction of duty committed by a lawyer.
Section 27 gives a special and technical meaning to the term, in consonance with the elementary notion
that the practice of law is a profession, not a business.

The commercialization of law practice is condemned in certain canons of professional ethics adopted by
the American Bar Association:

"34. Division of Fees. — No division of fees for legal services is proper, except with another lawyer,
based upon a division of service or responsibility."

"35. Intermediaries. — The professional services of a lawyer should not be controlled or exploited by
any law agency, personal or corporate, which intervenes between client and lawyer. A lawyer's
responsibilities and qualifications are individual. He should avoid all relations which direct the
performance of his duties by or in the interest of such intermediary. A lawyer's relation to his client
should be personal, and the responsibility should be direct to the client. . . ."

"38. Compensation, Commissions and Rebates. — A lawyer should accept no compensation,

As such, the Court imposed upon Atty. David the sanction of reprimand.

11. The Director of Legal Affairs v. Bayot

Facts:

Atty. Estanislao Bayot is charged with malpractice for having published an advertisement in the Sunday
Tribune, which reads: “license promptly secured thru our assistance & the annoyance of delay or
publicity avoided if desired, and marriage arranged to wishes of parties. Consultation on any matter free
for the poor. Everything confidential.”

Atty. Bayot at first denied having published the advertisement, but subsequently, thru his attorney, he
admitted having caused its publication and prayed for "the indulgence and mercy" of the Court,
promising not to repeat such professional misconduct in the future and to abide himself to the strict
ethical rules of the law profession.

Issue: Whether or not Atty. Bayot’s advertisement is ethical.

Held: No. The advertisement in question was a flagrant violation by Atty. Bayot of the ethics of his
profession, it being a brazen solicitation of business from the public. Section 25 of Rule 127 expressly
provides that "the practice of soliciting cases at law for the purpose of gain, either personally or thru
paid agents or brokers, constitutes malpractice." It is highly unethical for an attorney to advertise his
talents or skill as a merchant advertises his wares. Law is a profession and not a trade. The lawyer
degrades himself and his profession who stoops to and adopts the practices of mercantilism by
advertising his services or offering them to the public. As a member of the bar, he defiles the temple of
justice with mercenary activities as the money-changers of old defiled the temple of Jehovah. "The most
worthy and effective advertisement possible, even for a young lawyer, . . . is the establishment of a well-
merited reputation for professional capacity and fidelity to trust. This cannot be forced but must be the
outcome of character and conduct."

12. Petition for authority to continue use of the firm name “Sycip, Salazar, Feliciano, Hernandez, and
Castillo” and In the matter of the petition for authority to continue use of the firm name “Ozatea,
Romulo, De Leon, Mabanta & Reyes”
G.R. No. X92-1. July 30, 1979
Melencio-Herrera, J.

Facts:

Two separate Petitions were filed before this Court 1) by the surviving partners of Atty. Alexander Sycip,
who died on May 5, 1975, and 2) by the surviving partners of Atty. Herminio Ozaeta, who died on
February 14, 1976, praying that they be allowed to continue using, in the names of their firms, the
names of partners who had passed away.

Issue: Whether or not petitioners may be allowed to use the name of their deceased partners in their
firm name.

Held:

No. Article 1815 of the Civil Code provides that “every partnership shall operate under a firm name,
which may or may not include the name of one or more of the partners. Those who, not being members
of the partnership include their names in the firm name, shall be subject to the liability of a partner.” It
is clearly tacit in the said provision that names in a firm name of a partnership must either be those of
living partners and, in the case of non-partners, should be living persons who can be subjected to
liability.

Furthermore, a partnership for the practice of law cannot be likened to other professional partnerships.
A partnership for the practice of law is not a legal entity. It is a mere relationship or association for a
particular purpose. Thus, it has been stated that "the use of a nom de plume, assumed or trade name in
law practice is improper."

Finally, the possibility of deception upon the public, real or consequential, where the name of a
deceased partner continues to be used cannot be ruled out. A person in search of legal counsel might be
guided by the familiar ring of a distinguished name appearing in a firm title. In view of the personal and
confidential nature of the relations between attorney and client and the high standards demanded in
the canons of professional ethics, no practice should be allowed which even in a remote degree could
give rise to the possibility of deception.