LEGAL ETHICS- CASES

another woman, Cindy Villajuan, even reportedly marrying

William S. Uy v. Atty. Elerizza A. Libiran-Meteoro, A.C. No. 13368, her despite the existence of his marriage with complainant.
decided 21 May 2024, - Evidence submitted included: the marriage certificate
between complainant and respondent; birth certificate of their
Doctrine child; social media photos apparently showing respondent
- Attorneys must observe honesty, integrity, and upright conduct; and Cindy together and of a wedding; reservation slip for an
issuing worthless or dishonored checks constitutes gross alleged wedding; testimony from the venue owner
misconduct under the Code of Professional Responsibility and confirming February 20, 2015 wedding event.
Accountability (CPRA).
- Respondent failed to comply with multiple IBP-CBD
- Canon II, Sections 1 & 2 of the CPRA: duty to maintain high
directives: did not file an answer, failed to attend the
standards of professional conduct, refuse to engage in dishonest
mandatory conference, did not submit mandatory conference
acts, and avoid acts that undermine public trust.
brief or position paper.

Facts
Issues
- Complainant William S. Uy, representing Maliliw Lending
1. Whether the respondent is administratively liable for gross
Corporation, extended a personal loan to respondent Atty. Elerizza
immorality under the CPRA for abandoning his family, cohabiting
A. Libiran-Meteoro.
with another woman during the subsistence of his legitimate
- In late 2012, Libiran-Meteoro assured she would repay via post-
marriage, and publicly flaunting the illicit relationship.
dated checks. Uy accepted them based on her assurance.
2. Whether the respondent’s failure to comply with orders of the IBP-
- The checks were deposited, but dishonored with reasons
CBD (non-appearance, non-submission of briefs, etc.) aggravates
“ACCOUNT CLOSED” and “DAIF” (drawn against insufficient
his liability and justifies more severe sanction.
funds).
- Uy attempted to contact her about the dishonored checks, but she
Ruling
ignored his calls.
- Libiran-Meteoro had previously been suspended (in 2014) for - The Supreme Court found Atty. Vincenzo Nonato M.
gross misconduct in another case. Taggueg guilty of gross immorality for violating Sections 1
and 2, Canon II, and Canon VI of the CPRA.
Issues - The Court held that his abandonment of his legitimate family,
1. Did Atty. Libiran-Meteoro’s issuance of worthless checks cohabitation with another woman (Cindy Villajuan), and
constitute a breach of her professional responsibilities (i.e., gross publicly flaunting that relationship, are acts that show a
misconduct) under the CPRA? serious breach of moral character required of lawyers.
2. Is she administratively liable for failing to file her answer and - Respondent is disbarred, and his name is ordered stricken
mandatory conference brief? off the Roll of Attorneys, effective immediately.

Ruling Atty. Rojas v. Atty. Quiambao, A.C. No. 13496, 4 June 2024
- The Supreme Court found Atty. Elerizza A. Libiran-
Meteoro guilty of gross misconduct for issuing worthless Doctrine
checks. - Lawyers must maintain good moral character at all times. Grossly
- Her conduct was held to violate Canon II, Sections 1 & 2 of immoral conduct—such as extramarital affairs, sexual abuse, and
the CPRA. other scandalous acts—destroys public trust and
- She was disbarred (i.e. name struck off the Roll of warrants disbarment.
Attorneys), effective immediately.
- Also found guilty of violating rules of the Integrated Bar of Facts
the Philippines (IBP) for failure to report change of residence - Atty. Merriam Fe Rojas (complainant) and Atty. Lovejoy
or office address; fined ₱35,000. Quiambao (respondent) were married.
- Respondent was accused of abandoning his family, having
Manauis-Taggueg v. Taggueg, A.C. No. 13674, 1 August 2023
extramarital affairs, fathering illegitimate children, showing
pornographic materials to subordinates, and sexually abusing
Doctrine
employees, including minors.
- Lawyers must possess and maintain good moral
character throughout their practice. Conduct which is - He admitted to some acts of infidelity.
immoral or scandalous in private life can be ground for - The IBP found him guilty of grossly immoral conduct and
disbarment if it reflects adversely on the profession. recommended disbarment.
- Under the Code of Professional Responsibility and
Accountability (CPRA), grossly immoral conduct – including Issues
abandonment of legitimate family, cohabitation with another, 1. Is respondent liable for grossly immoral conduct under the CPRA?
and flaunting illicit relationships – can be a “serious offense” 2. What is the proper penalty?
warranting disbarment.
Ruling
Facts - Yes. Respondent is guilty of four counts of grossly immoral
- Monette Manauis-Taggueg (complainant) and Atty. Vincenzo conduct.
Nonato M. Taggueg (respondent) were legitimately married - Penalty: Disbarred and fined ₱400,000.
on June 6, 2002, and had a child.
- In 2016, Monette filed a complaint for disbarment alleging
that the respondent abandoned his family and cohabited with
LEGAL ETHICS- CASES

Kelley v. Atty. Robielos III, A.C. No. 13955, 30 January 2024 Santos v, Atty. Paña, A.C. No. 12353, 6 February 2024

Doctrine Doctrine
Issuing worthless checks, failing to pay debts, and disobeying IBP orders - A lawyer’s participation in falsification of court documents is a
are gross misconduct violating the CPRA and warrant disbarment. grave ethical violation and warrants disbarment.
- Under the Code of Professional Responsibility & Accountability
Facts
(CPRA), lawyers must not engage in unlawful, dishonest, immoral,
- Atty. Robielos borrowed ₱240,000 from Kelley and issued a check or deceitful conduct (Canon II, Rule 1.01), and must avoid conduct
that bounced. that adversely reflects on their fitness to practice law (Canon 7,
- He signed a settlement agreement but paid only ₱60,000, Rule 7.03).
leaving ₱180,000 unpaid.
- The MeTC ordered him to pay, but he evaded compliance. Facts
- He also ignored IBP-CBD directives in the administrative case. - Melody H. Santos hired Atty. Emilio S. Paña, Jr. for a annulment
(“nullity”) of marriage; she paid ₱280,000.
Issues - He provided her with documents purporting to be a Judgment
1. Is Robielos liable for gross misconduct for issuing a worthless (March 18, 2010) and a Certificate of Finality (April 14, 2010)
check and non-payment of debt? from RTC Branch 15, Cotabato City, which later turned out to
2. Is he liable for ignoring IBP-CBD orders? be inauthentic / falsified.
3. What is the proper penalty? - As a consequence, her visa application (K-1 visa in U.S.) was
denied when the documents were found fraudulent. She had to
Manmugay v. Atty. Dela Rosa, A.C. No. 11093, 14 November 2023 engage another lawyer and refile.
- When asked for refund, Atty. Paña returned ₱260,000, but not full
Ruling amount.
- Yes. He violated Canons II and III of the CPRA. - In his defense, Atty. Paña admitted referring Melody to a person
- Penalty: Disbarred, fined ₱35,000, and ordered to pay his debt. (“Guillermo”) who claimed to expedite annulment cases
improperly, apologizing for lack of prudence.
Doctrine
- Attorneys have a duty of loyalty, honesty, and due diligence toward Issues
their clients. Unauthorized sale or disposition of client property, 1. Did Atty. Paña commit gross misconduct by participating in
fraudulent notarization, and repeated violations of court orders falsification of judicial documents?
constitute gross misconduct under the Code of Professional 2. Did his misrepresentations and deceitful assurances to his client
Responsibility and related ethical rules. violate his duties under Lawyer’s Oath and the CPRA?
3. What is the appropriate penalty for such misconduct?
Facts
- Complainants Lucrecia Q. Mamugay and Perfecto O. Saliga Ruling
accused Atty. Elmer A. Dela Rosa of selling property belonging to - The Supreme Court held Atty. Paña guilty of violating the
them without their authorization. Lawyer’s Oath and CPRA for his involvement in falsified
- He allegedly executed fraudulent notarization in connection with annulment documents and misrepresentation.
that sale. - Penalty: Disbarment — his name is stricken off the Roll of
- He also repeatedly disobeyed court orders in the case. Attorneys, effective immediately.

Foodsphere Inc v. Atty. Melanio Mauricio, A.C. No. 7199, 22 July 2009
Issues
1. Did Atty. Dela Rosa commit professional misconduct by selling
Doctrine
property without client authorization?
2. Did he commit fraud via notarization in connection to that - Lawyers must avoid representing conflicting interests; accepting
unauthorized property transaction? employment from adverse parties without informed written consent
3. Is he administratively liable for disobeying court orders in the constitutes conflict of interest and is a violation of the Code of
matter? Professional Responsibility (Canon 15, Rule 15.03).

Ruling Facts
- The Supreme Court found Atty. Dela Rosa guilty of gross - Foodsphere, Inc. (CDO Foodsphere) hired Atty. Mauricio as legal
misconduct: unauthorized sale of client’s property, fraudulent counsel in labor cases involving company employees.
notarization, and repeated violation of court orders. - Later, Atty. Mauricio represented these same employees against
- Penalty: Disbarment — his name was stricken off the Roll of CDO Foodsphere in labor disputes.
Attorneys. - The company filed a disbarment complaint, claiming conflict of
interest and breach of professional duty.
- Atty. Mauricio argued he was engaged only as a “retainer” and was
not directly handling those cases.
Issues
1. Did Atty. Mauricio engage in conflict of interest by representing
employees against his former client, CDO Foodsphere?
LEGAL ETHICS- CASES
2. Is he administratively liable for violating the CPR? - Aspiras argued that his purchase was valid over the whole
property.
Ruling
- The Supreme Court ruled that Atty. Mauricio represented
conflicting interests by acting as counsel for employees in cases
adverse to CDO Foodsphere, which he previously served.
- His defense that he was only a retainer was rejected since the Issues
relationship of attorney-client existed. 1. Is the sale by one co-owner of the entire property valid as to the
shares of the other co-owners?
- Penalty: Suspension from the practice of law for six (6) months.
2. What rights does the buyer acquire in such case?
Atty. Antonio B. Manzano v. Atty. Carlos P. Rivera, A.C. No. 12173, 03
Ruling
November 2020
- The Supreme Court held that the sale by a co-owner is valid only
Doctrine with respect to the seller’s undivided share, but not as to the shares
of the other co-owners who did not consent.
- Lawyers are prohibited from representing conflicting interests
without the parties’ informed written consent (Canon 15, Rule - Thus, Aspiras acquired only the interest of the co-owner-seller, not
15.03, CPR). the entire property.
- Loyalty to a client survives the termination of the attorney-client - Partition may be demanded to determine the exact portion
relationship; counsel cannot use information from a former client corresponding to the seller’s share.
to the latter’s prejudice.
In Re: Atty. Gadon's Viral Video Against Raissa Robles, A.C. No. 13521,
Facts 27 June 2023
- Atty. Manzano engaged the services of Atty. Rivera in connection
Doctrine
with a property dispute involving the Philippine Veterans Bank.
- Lawyers must observe candor, civility, and propriety at all times,
- Later, Atty. Rivera appeared as counsel for the adverse party in a
whether in professional dealings or personal conduct.
related case against Manzano’s interest.
- Use of vulgar, sexist, or abusive language—even outside the
- Manzano filed a disbarment complaint, alleging betrayal of trust
courtroom—constitutes gross misconduct and a violation of
and conflict of interest.
the Code of Professional Responsibility and Accountability
- Rivera argued there was no lawyer-client relationship and that his (CPRA).
later representation was independent.
Facts
Issues
- A video went viral showing Atty. Lorenzo “Larry” Gadon hurling
1. Did Atty. Rivera represent conflicting interests in violation of the
profanities and sexist remarks against journalist Raissa Robles.
CPR?
2. Is he administratively liable for breach of loyalty and fidelity to a - The Integrated Bar of the Philippines and the Supreme Court
client? acted motu proprio to investigate the matter.
- The Court noted that this was not the first time Atty. Gadon
Ruling engaged in offensive and scandalous behavior, as he had previous
- The Supreme Court found that an attorney-client relationship administrative cases for similar misconduct.
existed between Manzano and Rivera, even if only for
consultation. Issues
1. Did Atty. Gadon’s remarks in the viral video constitute gross
- Rivera’s later representation of the adverse party
misconduct and violation of the Lawyer’s Oath and CPR?
constituted conflict of interest, violating his duty of loyalty.
2. Should he be disciplined despite his claim that the statements were
- Penalty: Suspension from the practice of law for one (1) year. made in his private capacity?

Mortel v. Aspiras, G.R. No, L-9152, 28 December 1956 Ruling

- The Supreme Court ruled that Atty. Gadon’s public use of vulgar,
Doctrine
misogynistic, and abusive language was gross misconduct and a
- Co-ownership: The sale by one co-owner of the entire property serious violation of professional ethics.
without the consent of the others is valid only as to his share, and
- The Court emphasized that a lawyer’s duty to uphold dignity and
transfers no rights over the shares of the other co-owners.
respect applies at all times, not only in professional engagements.
- Partition: Each co-owner may demand partition at any time, but
- Penalty: Disbarment — Atty. Gadon’s name was ordered stricken
such partition must respect the lawful shares of all co-owners.
off the Roll of Attorneys.
Facts
- The property in dispute was co-owned by the heirs of a deceased
person, including petitioner Mortel.
- Respondent Aspiras bought the entire property from one of the co-
owners.
- Mortel contested the sale, claiming it prejudiced the rights of the
other co-heirs who did not consent.
LEGAL ETHICS- CASES
- Any penalty related to her acts as a legislator must come from her
Barandon v. Ferrer, Sr., A.C. No, 5768, 26 March 2010 own chamber.
- Case dismissed for lack of jurisdiction.
Doctrine
- Lawyers must not use their professional position to harass, Areola v. Atty. Mendoza, A.C. No. 10135, 15 January 2014
threaten, or abuse others; such conduct constitutes gross
misconduct and is a violation of the Code of Professional Doctrine
Responsibility.
- A lawyer’s failure to file pleadings, attend hearings, and update his
- The Lawyer’s Oath requires attorneys to act with civility, propriety, client on the status of a case constitutes gross negligence and
and integrity at all times. violation of the Code of Professional Responsibility (Canon 18,
Rule 18.03 & 18.04).
Facts
- Lawyers must serve clients with competence, diligence, and
- Complainant Barandon alleged that Atty. Jose C. Ferrer, fidelity; neglect of legal matters is a ground for disciplinary
Sr. harassed and threatened him with abusive language and sanction.
arrogant behavior.
- The incidents showed Ferrer’s use of his standing as a lawyer to Facts
intimidate others. - Complainant Jose Areola engaged Atty. Francisco P. Mendoza to
- The case reached the Supreme Court through a complaint for represent him in a civil case.
professional misconduct. - Atty. Mendoza failed to file necessary pleadings and appear at
hearings, causing the dismissal of his client’s case.
Issues
- He also failed to inform his client of the status of proceedings
1. Did Atty. Ferrer’s acts of harassment and abusive language
despite repeated inquiries.
constitute gross misconduct?
2. Is he administratively liable under the CPR and the Lawyer’s - Areola filed a complaint for negligence and incompetence in
Oath? handling his case.
- Atty. Mendoza did not offer any credible defense.
Ruling
- The Supreme Court found that Atty. Ferrer engaged in conduct Issues
unbecoming of a lawyer by threatening and using offensive 1. Was Atty. Mendoza guilty of gross negligence and incompetence in
language, violating his oath and professional ethics. handling his client’s case?
2. Should he be held administratively liable under the CPR?
- Such acts eroded public confidence in the legal profession.
- Penalty: Suspension from the practice of law for six (6) months. Ruling
- The Supreme Court held Atty. Mendoza liable for gross
Pobre v. Senator Santiago, A.C. No. 7399, 25 August 2009
negligence in failing to protect his client’s interests and for failure
to communicate properly.
Doctrine
- His neglect violated the Lawyer’s Oath and the CPR.
- The Supreme Court cannot discipline incumbent Members of
Congress (Senators or Representatives) for misconduct due to the - Penalty: Suspension from the practice of law for two (2) years,
constitutional principle of separation of powers. with a warning that repetition will warrant more severe sanctions.
- Alleged misbehavior of legislators must be addressed by their
Falcis III v. Civil Registrar General, G.R. No. 217910, 03 July 2018
respective Houses through internal disciplinary mechanisms (Art.
VI, Sec. 16[3], 1987 Constitution).
Doctrine

Facts - Judicial review requires an actual case or controversy; courts do

not render advisory opinions.
- Complainant Pobre sought to disbar Senator Miriam Defensor-
Santiago for alleged “unbecoming conduct” and use of - A petitioner must have legal standing and must show direct injury;
intemperate, abusive language in public. otherwise, the case will be dismissed for lack of jurisdiction.
- He claimed her actions violated the Code of Professional - The constitutionality of the Family Code provisions limiting
Responsibility and the Lawyer’s Oath. marriage to a man and a woman cannot be resolved through a
petition filed by one without standing.
- The complaint was filed before the Supreme Court while she was
still serving as a Senator.
Facts

Issues - Atty. Jesus Nicardo Falcis III, an openly gay lawyer, filed
1. Can the Supreme Court discipline a sitting Senator for alleged a petition for certiorari and prohibition assailing Articles 1 and 2 of
misconduct in connection with her public statements? the Family Code, which restrict marriage to unions between a man
2. Does her conduct constitute a ground for disbarment or suspension and a woman.
from the practice of law? - He argued that these provisions violated the equal protection
Ruling clause and the constitutional guarantees of liberty and privacy.
- The Supreme Court dismissed the complaint. - No actual application for a marriage license was made, nor was
- It held that the Court cannot discipline an incumbent there a concrete case involving denial of marriage to same-sex
Senator because she is subject to the disciplinary authority of couples.
the Senate, not the judiciary, in line with the doctrine of separation
of powers.
LEGAL ETHICS- CASES
- The Office of the Solicitor General (OSG) argued that Falcis statements, etc.) for acting in an unlawful, dishonest, immoral and
lacked standing and that the petition raised no justiciable deceitful manner.
controversy. - Penalty: Suspended from the practice of law for three (3) years,
effective immediately upon receipt of the decision, with a stern
Issues warning that repetition or similar acts will merit a more severe
1. Does the petition present an actual case or controversy for judicial sanction.
review?
2. Does Falcis have legal standing to question the constitutionality of
the Family Code provisions on marriage?
3. Are the Family Code provisions limiting marriage to a man and a Brozas-Garri v. Atty. Reago, A.C. No. 11428, 13 November 2023
woman unconstitutional?
Doctrine
Ruling - A notary public must notarize documents only if the signatory
- The Supreme Court dismissed the petition. personally appears before the notary and either is known or
- It held that there was no actual case or controversy since Falcis did properly identified by the notary.
not apply for a marriage license nor was there a concrete denial of - Forged signatures and improper notarization are dishonest and
rights. deceitful conduct, violating both the Notarial Rules and the Code
- Falcis lacked legal standing because he failed to show direct injury of Professional Responsibility & Accountability (CPRA),
from the questioned provisions. particularly Canon II (Sections 1 and 11).
- The Court stressed that constitutional issues cannot be resolved in
Facts
the absence of a real, ripe dispute.
- Maria Brozas-Garri (complainant) filed a complaint against Atty.
- Petition dismissed; however, the Court recognized that the matter
Lorenzo A. Reago for:
of same-sex unions is a policy question properly addressed by
1. Failing to return her owner’s duplicate copy of Transfer
Congress.
Certificate of Title (TCT No. 8458) which he borrowed.
2. Preparing and notarizing a Special Power of Attorney (SPA)
Paez v. Atty. Debuque, A.C. No. 13628, 28 May 2024
authorizing his wife to enter into a lease contract over her property,
bearing Brozas-Garri’s forged signature, while she was abroad.
Doctrine
3. Failing to file appellees’ brief and status report in a case
 Under the Code of Professional Responsibility and Accountability
where he acted as primary counsel for Brozas-Garri and co-
(CPRA), a lawyer shall not engage in unlawful, dishonest, immoral
appellants.
or deceitful conduct (Canon II, Section 1).
- In defense, Reago claimed the title was returned via the
 Lawyers must make no false representations or statements and
complainant’s sister; that the SPA was prepared according to her
correct them when discovered; they must observe dignity, fairness,
instruction; that she had knowledge; and that some of the
obedience to law, and respect for clients’ vulnerable situations.
deficiencies were due to her failure to follow-up.

Facts
Issues
 Helen A. Paez owned a lot in Iloilo, mortgaged for a ₱300,000
1. Did Atty. Reago engage in improper notarization of a forgery
loan. While incarcerated, she entered into an agreement with Atty. (SPA) and violate the Notarial Rules?
Alfonso D. Debuque to sell the property to him, with part of the 2. Did he commit dishonest or deceitful conduct in his capacity as
price to settle the mortgage. lawyer for failing to properly safeguard documents, respond to
 Three deeds of sale were executed with differing terms: demands, file briefs/status reports, etc.?
1. A deed with “Assignment of Mortgage,” total ₱500,000 3. What are the proper disciplinary penalties for such misconduct?
(₱300,000 to bank + ₱200,000 to Paez).
2. A deed of sale for ₱300,000 to be paid to Paez, with buyer Ruling
(Debuque) paying taxes etc.  The Supreme Court found Atty. Reago guilty of violating the 2004
3. Another deed of absolute sale (third deed) signed by Paez Rules on Notarial Practice and Canon II of the CPRA (Sections 1
alone, similar to the second deed’s terms. & 11).
 Debuque failed to pay the full consideration, claimed payments  Penalty imposed:
were made in installments, and later contradicted himself in • Suspended from the practice of law for two (2) years
different court‐submissions about whether full payment had been • His notarial commission is revoked (if still subsisting)
made. He also advised the use of different deeds possibly to avoid • Disqualified from being commissioned as a notary public
tax penalties. for two (2) years
 He was also sternly warned that similar acts in the future would
Issues
warrant more severe sanctions.
1. Did Atty. Debuque violate his duties under the CPRA by engaging
in deceitful and dishonest transactions (e.g., multiple deeds with
Leda v. Atty. Tabang, A.C. No. 2505, 21 February 1992
conflicting terms, false statements regarding payment)?
2. Given Paez was incarcerated and vulnerable, was there an abuse of
Doctrine
her situation to her detriment?
3. What penalty is appropriate for the misconduct established? - Lawyers are expected to act with utmost honesty, integrity, and
good faith in dealing with their clients.
Ruling - Failure to return money received for a client’s cause and disregard
- The Supreme Court found Atty. Debuque guilty of violating CPRA of lawful orders of the Court constitute gross misconduct, violating
(Canon II, Section 1, and related sections on dignity, falsity of the lawyer’s oath and Canons of Professional Ethics.
LEGAL ETHICS- CASES
Facts
- Complainant Marcelino Leda engaged Atty. Tabang to appeal his
case pending before the Supreme Court.
- Leda gave Tabang ₱2,000 for filing expenses.
- Despite receiving the money, Tabang failed to file the intended
pleading and did not return the money despite repeated demands.
- Even after being required by the Supreme Court to answer the
complaint, Tabang ignored the Court’s directivesand did not file
any explanation or comment.

Issues
1. Did Atty. Tabang commit professional misconduct by failing to file
the intended pleading and by not returning the client’s money?
2. Should he be disciplined for ignoring the orders of the Supreme
Court?

Ruling
 Yes. The Court found Atty. Tabang guilty of gross
misconduct and serious violation of the lawyer’s oath.
 His failure to return the client’s money and his disregard of Court
orders showed lack of integrity and respect for the legal profession.
 Penalty: He was disbarred and his name was ordered stricken off
the Roll of Attorneys.