Perez vs.

Lantin
Occea vs. Marquez
People vs. De Luna

Ui v. Bonifacio
Immoral Conduct
Facts:
Leslie Ui filed an administrative case for disbarment against Atty. Iris Bonifacio on the
grounds of immoral conduct stating that Atty. Bonifacio is allegedly having an illicit
relationship with her husband, Carlos Ui, whom she has 2 children with. She alleged that
Carlos admitted to the existence of the affair in which she asked him to end it.
Respondent contested that she is the victim. When she met Carlos, she thought he was a
bachelor but with children to an estranged Chinese woman who is already in Amoy, China.
Moreover, the two got married in Hawaii, USA therefore legalizing their relationship. When
respondent knew of his real status, she ended their relationship. Respondent further
claimed that they never lived together as the latter lived with his children to allow them to
gradually accept the situation. Respondent however presented a misrepresented copy of
her marriage contract in the proceeding before the IBP Commission on Bar Discipline stating
that she and Carlos got married in 1985 but according to the certificate of marriage
obtained from the Hawaii State Department of Health, they were married in 1987.
Issue:
Whether or not Atty. Iris Bonifacio conducted herself in an immoral manner for which she
deserves to be barred from the practice of law.
Ruling:
No. The practice of law is a privilege. The bar candidate does not have the right to enjoy the
practice of the legal profession simply by passing the bar, he must also have a continued
possession of good moral character. A lawyer may be disbarred for grossly immoral conduct
, which has been defined as the conduct which is willful, flagrant, or shameless, and which
shows a moral indifference to the good and respectable members of the community.
Lawyers, as keepers of public faith, are burdened with a higher degree of social
responsibility and thus must handle their personal affairs with great caution.
Iris Bonifacio was imprudent in managing her personal affairs. However the fact remains
that her relationship with Carlos, clothed as it was with what she believed as a valid
marriage, cannot be considered immoral. Immorality connotes conduct that shows
indifference to the moral norms of society and the opinion of good and respectable
members of the community. For such conduct to warrant disciplinary action, it must be
grossly immoral, it must be so corrupt and false as to constitute a criminal act or
unprincipled as to be reprehensible to a high degree.
A lawyer is not only required to refrain from adulterous relationships but must also behave
himself as to avoid scandalizing the public by creating the belief that he is flouting those
moral standards. Her act of distancing herself on her discovery that Carlos was married
proves that she had no intention of flaunting the law and the high moral standard of the
legal profession.
On the matter of the falsified marriage certificate, it is contrary to human experience and
highly improbable that she did not know the year of her marriage or she failed to check that
the information on the document she attached to her Answer were correct. Lawyers are
called upon to safeguard the integrity of the Bar, free from misdeeds and acts of
malpractice.

Narido vs. Linsangan

Mutual Bickering Between Opposing Counsels
Facts:
58 SCRA 85 Legal Ethics Mutual Bickering Between Opposing Counsels
Atty. Rufino Risma represented Petitioner Flora Narido, an indigent client, against her
employer Vergel De Dios, who is then represented by Atty. Jaime Linsangan. During the
hearing, an affidavit executed by the employer was vehemently opposed by De Dios as Atty.
Risma believed it to be perjured. Such vehemence resulted to threatening Atty. Linsangan of
a disbarment case if said affidavit is filedwhich did happen.
Aty. Linsansangan the filed a separate admisnistrative case against Atty. Risma for
instigating the client to file a groundless case against him, in order to spite him, and is
merely a scheme to threaten him and to ensure an advantage over him.
Issue:
Whether or not both cases should prosper.
Ruling:
No. Supreme Court, as per findings of the Solicitor General, held the cases unmeritorious.
In the administrative case against Linsangan, it was found out that there is no sufficient
evidence to prove that De Dios affidavit is perjured. Or if even so, there is no showing that
Linsangan was in bad faith for it was not proven that he has the intention of misleading the
court.
In the administrative case against Risma, it was not proven that he instigated Narido. It was
Rismas zeal in protecting his clients interest that made him to convince Narido to file an
administrative case against Linsangan. There was no bad faith on the part of Risma. He
even advanced the expenses because Narido is indigent.
HOWEVER, it was found that Risma made an arrangement with Narido that he shall collect
15% from whatever amount they shall collect from De Dios as a result of the labor case.
Risma was admonished for this; that under the Workmens Compensation Act, hes only
allowed to collect a maximum of 10%. Hes advised to keep abreast of said law and noted
that the contract for attorneys fees should not be enforced. What was recommended
commends itself for acceptance.
xxxThe two respondents would be well- advised 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. xxx

Laput vs. Remotigue

Facts:

Blanza vs. Arcangel

Volunteer
Facts:
On April 1955, Atty. Agustin Arcangel volunteered to help the Olegario Blanza and Maria
Pasion with their pension claims from the death of their soldier-husbands. So petitioners
gave the respondent the necessary documents and signed blank documents. 6 years later,
as progress stalled, the former asked for the return of the said documents however,
Arcangel refused.
Respondent contended before Fiscal Raa as per recommendation of the Solicitor General
that the documents were for photostating purposes only. The petitioners failed to pay for
the Photostat costs, hence the delay for its return.
Anyway, he advanced the expenses himself to get the documents on December !966.
Fiscal Raa recommended in favor of Arcangel but Solicitor General thought that the
Respondent deserved a severe reprimand for:
(1) his failure to attend to complainants' pension claims for six years;
(2) his failure to immediately return the documents despite repeated demands upon him,
(3) his failure to return to complainant Pasion, allegedly, all of her documents.
During the hearing, respondent submitted an affidavit executed by Blanza asking for the
dismissal of the case.
Issue:
1. Can Atty. Agustin Arcangel be held liable?

Ruling:
No. There is no clear preponderance of evidence to substantiate the accusations against
Arcangel.
1. Arcangel is bound to attend to complainants claims with all due diligence since he
volunteered and attorney-client relationship has been established, even if there was no
agreement for the compensation.
2. Complainants are partly at fault for the delay due in failing to cooperate and pay for the
Photostat service.
3. As for the alleged failure to return the documents, Fiscal Raa made no findings on the
matter.
The affidavit presented cannot prejudice Mrs. Pasion. The principle of res inter alios acta
alteri nocere non debet applies. However, neither she nor her counsel appeared on the later
hearings.
xxxCourt cannot help but counsel against his actions as a member of the bar. A lawyer has
a more dynamic and positive role in the community than merely complying with the
minimal technicalities of the statute. As a man of law, he is necessarily a leader of the
community, looked up to as a model citizen. His conduct must, perforce, be par excellence,
especially so when, as in this case, he volunteers his professional services. Respondent here
has not lived up to that ideal standard. It was unnecessary to have complainants wait, and
hope, for six long years on their pension claims. Upon their refusal to co-operate,
respondent should have forthwith terminated their professional relationship instead of
keeping them hanging indefinitely. And although we voted that he not be reprimanded, in a
legal sense, let this be a reminder to Atty. Arcangel of what the high standards of his chosen
profession require of him. Accordingly, the case against respondent is dismissed. So
ordered. xxx

6 SCRA 45 Legal Ethics Client Grabbing

In 1952, Atty. Laput was retained by Nieves Barrera as counsel in a testate
proceeding. He remained as counsel for three years. But in January 1955, Atty.
Fortunato Patalinghug filed his written appearance as new counsel for Barrera.
When Laput found out about Patalinghugs appearance, he voluntarily asked the
court to be relieved as counsel for Barrera on February 5, 1955. On February 7,
1955, Atty. Remotigue also filed his appearance as additional counsel for Barrera.
Laput is now charging the two lawyers of unethical and improper appearances for
Barrera; that they influenced her to replace Laput as her counsel; that they caused
her to disauthorize him as counsel for her; that the purpose of said lawyers is to
embarrass Laput to the officials and employees of the corporations owned by the
estate subject of the testate proceedings.
ISSUE: Whether or not there is encroachment of client in the case at bar.
HELD: No. It was found out that Barrera herself caused the filing of a pleading to
discharge Laput as her counsel. Barrera did this because she lost trust and
confidence in Laput. She lost trust in Laput because she found out that there were
some dividend checks that were supposed to be sent to her but Laput took said
checks as his own hence she felt cheated.
Thereafter, she went to the law office of Remotigue and Patalinghug where she
arranged a contract. The fact that Laput voluntarily asked the court to discharge
him as counsel for Barrera after Patalinghug filed his entry of appearance showed
Laputs acquiescence to Patalinghugs appearance as counsel for Barrera. This
should estop petitioner from now complaining that the appearance of Atty.
Patalinghug was unprofessional. On the part of Remotigue, there can be no
irregularity for he filed his entry of appearance only after Laput was discharged as
counsel for Barrera.
Laput used to be the counsel for Nieves Barrera until the latter discharged her
because she lost trust and confidence in him due to dubious transactions that
Laput handled while representing her in a testate proceeding. One of the lawyers
retained by Barrera to replace Laput was Remotigue. In September 1957,
Remotigue, without notice to Laput, asked the court to direct Laput to turn over
certain documents and titles to Barrera so that the latter may properly disposed
some estate properties. The court granted the same. But Laput stubbornly kept the
said documents as he claimed that said estate properties are subject to his lien and
that he needs to be paid first.
ISSUE: Whether or not Laput has the right to keep said documents.

HELD: No. It turns out that Laputs attorneys fees were already significantly paid
while he was still the counsel for Barrera (as backed by evidence presented by
Remotigue) hence he no longer has a lien to the properties of the estate. Therefore,
he cannot retain the certificates of title in question. On another note, he cannot
now charge Remotigue with malice and bad faith when the latter filed without
notice of Laput motions to direct Laput to surrender said certificates because as
records proved, even though no notice was sent to him, he had regularly checked
on the record of this case hence he would have come across the same.