G.R. No. 215955 - Metropolitan Waterworks and Sewerage System vs. Central Board of Assessment Appeals

On 02 October 1997, Epifania Q. Bantolo filed a letter-complaint with the Integrated Bar of the Philippines (IBP) against Atty. Egmedio B. Castillon, Sr.
Complainant charged that respondent violated the lawyer’s oath and Section 20 of Rule 138 of the Rules of Court by:

Wittingly or willingly performing, promoting, or suing a groundless, false, or unlawful suit, or giving aid or consent to such action;
Delaying the execution of the suit without legal or justifiable cause and employing illegal means to do so;
Disobeying lawful orders of the Regional Trial Court, thereby showing blatant disrespect; and
Employing unlawful and illegal means to attain his ends.

The controversy centered on a parcel of land in Valderrama, Antique, where respondent was also one of the defendants.
The civil case resulted in a decision in favor of Bantolo and her co-plaintiffs, leading to the issuance of a writ of execution and the ejection of the defendants from the property.
Despite the writ, respondent and his co-defendants reentered the disputed property and proceeded to harvest the palay planted therein, thus aggravating the situation.

In response to the defiant act of reentering the property, the plaintiffs moved for the defendants to be declared in contempt for willful disobedience of lawful court orders.
On 25 January 1991, the trial court found Atty. Castillon and his co-defendants guilty of indirect contempt of court, imposing a penalty of one month imprisonment along with a fine.
The Court of Appeals, on 26 July 1994, affirmed the trial court’s decision but modified the penalty by replacing imprisonment with a fine of P1,000.00 for each defendant.

In his Answer to the Complaint dated 02 March 1998, respondent denied all allegations, asserting that the complaint was merely a form of harassment.
Despite scheduling hearings, the proceedings were subject to repeated cancellations and resets due to the unavailability of the complainant, with a hearing for the presentation of her evidence convened on 09 December 1998.
Although notices were sent to respondent to set his hearing for presenting evidence, he failed to appear or inform the IBP of his new office address, effectively waiving his right to present evidence.

On 17 March 2004, Atty. Rafael Antonio M. Santos, the investigating commissioner, submitted the Report and Recommendation.
The Report noted that Bantolo did not prove that respondent’s actions during his defense of the case were outside the bounds of the law, emphasizing that losing the trial did not automatically substantiate charges of promoting or instituting a groundless or unlawful suit.
The investigative findings primarily focused on respondent’s contumacious conduct as established in the trial court and affirmed by the Court of Appeals.
The Report specifically highlighted respondent’s attempts to:

Mislead the Commission on Bar Discipline by suggesting that contempt charges were still pending when in fact they had been terminated;
Unduly emphasize the alleged lack of personality of the complainant as a basis for dismissing her complaint; and
Fail to notify the Commission of his change of address.

Based on these findings, and recognizing that the circumstances did not warrant the supreme penalty of disbarment, the Commission recommended a penalty of suspension for one (1) month.

On 30 July 2004, the IBP adopted the Report and Recommendation, formalizing its findings in Resolution No. XVI-2004-376.
The Resolution reiterated that respondent, having been found by both the trial court and the Court of Appeals guilty of indirect contempt for disobedience of the writ of execution and for attempting to mislead the Commission, was suspended from the practice of law for one (1) month.
The resolution underscored the fundamental obligation of lawyers to obey court orders, emphasizing that any act of defiance or obstruction constitutes not only contempt of court but also professional misconduct subject to disciplinary sanctions.
A stern warning was issued that any repetition of such misconduct would result in more severe penalties, potentially including disbarment.
The disciplinary action was thus portrayed as both punitive and corrective, aiming to restore the integrity expected of a member of the legal profession.

Whether respondent’s actions, particularly his willful reentry of the property after a court-ordered writ of execution and his subsequent conduct, constitute contumacious behavior amounting to a violation of his sworn duties as a lawyer.

Did the respondent’s conduct of reentering the property and harvesting the palay, despite the writ of execution, reflect a blatant disregard for the court’s lawful orders?
Does his failure to notify the IBP of his change of address, resulting in a waiver of his right to present evidence, further demonstrate his indifference to procedural obligations?

Whether the penalty of suspension for one (1) month is a just and appropriate sanction for the misconduct demonstrated by respondent or whether a harsher penalty, such as disbarment, should be imposed given the gravity of his actions.

Is a one-month suspension sufficient to address the implications of his contumacious behavior as an officer of the court?
How do the principles of proportionality and the objective of rehabilitating rather than permanently excluding a lawyer from the profession factor into the disciplinary decision?