Case Digest (A.C. No. 10498) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In A.C. No. 10498, decided on May 27, 2019 under the 1987 Constitution, the Solicitor General–designated En Banc of the Supreme Court evaluated a Verified Complaint–Affidavit filed by Judge Ariel F. Dumlao, Jr., presiding judge of the Regional Trial Court, Branch 42, Dagupan City, against Atty. Manuel N. Camacho. Camacho acted as counsel for Pathways Trading International, Inc. in CV–2004–0181-D, Pathways v. Univet Agricultural Products, Inc., et al. On January 30, 2014, the RTC granted summary judgment in favor of Pathways, ordering defendants to pay ₱16,000,000 plus 10% attorney’s fees. Defendants, through new counsel Atty. Geraldine Baniqued, filed a notice of appeal. Thereafter, respondent repeatedly tried to influence Judge Dumlao by name-dropping alleged friendships with Chief Justice Sereno, Associate Justice Leonen, and President Aquino III, and by offering a portion of his attorney’s fees in exchange for denying the appeal and issuing the writ of execution. When the wri Case Digest (A.C. No. 10498) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Case Background
- Complainant: Presiding Judge of Regional Trial Court (RTC), Dagupan City, Branch 42, handling CV-2004-0181-D (Pathways Trading International, Inc. vs. Univet Agricultural Products, Inc., et al.).
- Respondent: Atty. Manuel N. Camacho, counsel for plaintiff Pathways.
- Proceedings in the Underlying Civil Case
- January 30, 2014 – RTC grants plaintiff’s motion for summary judgment, awarding:
- P16,000,000 reimbursement;
- 10% attorney’s fees;
- costs of litigation.
- Defendants, through new counsel Atty. Geraldine Baniqued, file notice of appeal; RTC denies appeal (April 1, 2014) for lack of proper substitution.
- April 28, 2014 – RTC issues Certificate of Finality and Writ of Execution.
- Alleged Misconduct by Respondent
- Influence peddling: fraternizes with judge, drops names of Supreme Court Justices (Sereno, Leonen) and UP Law connections.
- Attempted bribery: phone calls promising to share legal fees if judge denies appeal and issues execution; threats of disbarment if refused.
- Chamber intrusion (May 22, 2014): demands court sheriff sign a garnishment order drafted by respondent; menacing language against sheriff.
- Text messages to judge accusing him and sheriff of graft and warning of imminent pleadings.
- Disciplinary Proceedings
- Verified Complaint-Affidavit filed before Office of the Bar Confidant; respondent fails to file comment.
- IBP Commission on Bar Discipline (May 10, 2016) finds respondent guilty, recommends disbarment; IBP Board (Resolution No. XXII-2017-1186) adopts facts but reduces penalty to six-month suspension.
- Supreme Court accepts facts, modifies penalty to two-year suspension—subject to recording only due to respondent’s prior disbarment.
Issues:
- Did respondent commit influence peddling and attempted bribery in violation of Canon 13 (Rule 13.01) and Canon 10 (Rule 10.01) of the Code of Professional Responsibility?
- Did respondent threaten and disrespect court officers and processes in violation of Canon 11 (Rule 11.03) and Canon 19 (Rule 19.01) of the Code?
- What is the appropriate disciplinary penalty, considering respondent’s prior disbarment?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)