A.C. No. 10627 - Gonzales, Jr. vs. Rivera and Bangoy

In the 2012 Decision in Villatuya v. Atty. Tabalingcos, the Court disbarred Atty. Bede S. Tabalingcos for engaging in bigamy.
The Motion for Reconsideration filed by Tabalingcos was denied with finality on August 28, 2012, and he received a copy of this Resolution on October 2, 2012.
Despite disbarment, Tabalingcos continued to perform acts constituting unauthorized practice of law, including filing motions for extension dated September 18, 2012 and October 18, 2012 in an administrative case before the Bangko Sentral ng Pilipinas (BSP case).

Complainants Reno R. Gonzales, Jr. and Bryan F. Concepcion filed a Letter-Request informing the Court of Tabalingcos's unauthorized practice and requested investigation of respondents, his associates Socrates Rivera and Cres Dan Bangoy, for violation of Canon 9 of the Code of Professional Responsibility (CPR).
Bangoy co-signed the Motion for Extension on October 18, 2012 under the Tabalingcos and Associates Law Office despite Tabalingcos's disbarment.
Rivera signed the Notice of Change of Address dated December 2, 2013 as co-counsel in the BSP case.
Complainants alleged respondents misrepresented to the public that Tabalingcos was still authorized to practice law.

Bangoy filed a Comment denying knowledge or participation in Tabalingcos’s unauthorized practice, claiming he left the firm in August 2012 prior to the motion filing.
Rivera failed to file a comment despite being ordered.
The Court fined Rivera PHP 1,000 and ordered him to comply with directives; he failed to pay the fine or file the comment.
The Office of the Bar Confidant (OBC) recommended Rivera be suspended for six months, pay the fine, and impose an additional PHP 10,000 fine due to repeated defiance, but noted Rivera was already disbarred.

The Court applied the Code of Professional Responsibility and Accountability (CPRA), effective May 30, 2023, for resolution.
Bangoy was found guilty of assisting in unauthorized practice by knowingly co-signing pleadings with disbarred Tabalingcos.
Rivera was not found liable for assisting unauthorized practice merely for signing a Notice of Change of Address as co-counsel.
Rivera’s failure to comply with court orders and non-payment of fines constituted gross misconduct and insubordination, meriting a fine of PHP 50,000.

Whether respondents, particularly Rivera and Bangoy, are administratively liable for assisting Atty. Tabalingcos in practicing law without authorization following his disbarment.
Whether the act of signing pleadings or notices under a law office that includes a disbarred lawyer constitutes violation of professional responsibility and ethical rules.
The appropriate penalties for respondents, considering their actions and compliance with Court directives.