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BLE11 - OCA - V - Atty - Ladaga

This document summarizes an administrative case filed against Atty. Ladaga, a clerk of court who represented his cousin in a criminal case without prior authorization. The Supreme Court denied Atty. Ladaga's request to represent his cousin pro bono and directed the OCA to file charges against him. While Atty. Ladaga admitted to representing his cousin without permission due to her lack of resources, the Court still reprimanded him with a warning for failing to obtain written permission from the OCA first. The Court clarified that an isolated court appearance does not constitute private practice but cautioned against habitually holding oneself out as a lawyer without proper authorization.

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Cedric Kho
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96 views1 page

BLE11 - OCA - V - Atty - Ladaga

This document summarizes an administrative case filed against Atty. Ladaga, a clerk of court who represented his cousin in a criminal case without prior authorization. The Supreme Court denied Atty. Ladaga's request to represent his cousin pro bono and directed the OCA to file charges against him. While Atty. Ladaga admitted to representing his cousin without permission due to her lack of resources, the Court still reprimanded him with a warning for failing to obtain written permission from the OCA first. The Court clarified that an isolated court appearance does not constitute private practice but cautioned against habitually holding oneself out as a lawyer without proper authorization.

Uploaded by

Cedric Kho
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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A.M. No.

P-99-1287 January 26, 2001 FIRST DIVISION


MENDOZA, J.

OFFICE OF THE COURT ADMINISTRATOR, petitioner,


vs.
ATTY. MISAEL M. LADAGA, respondent.

FACTS: Atty. Ladaga is a Clerk of Court from the Makati RTC, Branch 133. He requested
the OCA for authority to appear as pro bono counsel for his cousin’s (Narcisa Naldoza
Ladaga) criminal case. He admitted that he has appeared in court representing his cousin
without prior authorization but explained that the factual circumstances surrounding the
criminal case compelled him to handle the defense of his cousin who did not have enough
resources to hire the services of a lawyer. The Court denied his request and directed the
OCA to file administrative charges against him for appearing in court without the required
authorization of the Court.
In reply, Atty. Ladaga explained that Lisa Andres, the complainant against Atty.
Ladaga’s cousin, was seeking vengeance against his cousin Narcisa for having an illicit
relationship with the Andres’ husband.

ISSUE: Whether or not Atty. Ladaga be allowed to represent his cousin.

HELD: No. The Court sided with petitioner’s recommendation of having Atty. Ladaga be
reprimanded. The Court explained that the “private practice” mentioned in the Revised
Rules of Court does not pertain to Atty. Ladaga’s isolated court appearances. They
reasoned, “It should be clarified that "private practice" of a profession, specifically the law
profession in this case, which is prohibited, does not pertain to an isolated court
appearance; rather, it contemplates a succession of acts of the same nature habitually or
customarily holding one's self to the public as a lawyer.”

Regardless, the Court still had him “reprimanded with a stern warning” for failing
to obtain a written permission from the OCA.

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