Title
IN RE: Gadon
Case
A.C. No. 13521
Decision Date
Jun 27, 2023
Atty. Gadon disbarred for repeated use of vulgar, offensive language, gender-based harassment, and contemptuous behavior, violating professional ethics and legal standards.

Case Digest (A.C. No. 13521)
Expanded Legal Reasoning Model

Facts:

  • Initiation of administrative case
    • The Supreme Court en banc, pursuant to Section 27, Rule 138 of the Rules of Court, took cognizance of a viral video clip showing Atty. Lorenzo G. Gadon uttering profanities and obscene remarks against journalist Raissa Robles while inside a parked car.
    • In a January 4, 2022 Resolution, the Court ordered him to show cause why he should not be disbarred and placed him on preventive suspension.
  • Prior misconduct noted by the Court
    • Vowed mass violence against Muslim communities if they did not cooperate in anti-insurgency efforts and threatened to exterminate civilians.
    • Publicly insulted supporters of former Chief Justice Sereno, flashed his middle finger, and declared indifference to disbarment.
    • Made malicious statements during the Sereno impeachment proceedings and falsely imputed that former President Aquino died of HIV.
  • Atty. Gadon’s Comment and defenses
    • Challenged preventive suspension as violative of due process under Section 15, Rule 139-B of the Rules of Court.
    • Alleged singling out compared to other public figures (Sen. De Lima, Atty. Diokno) and moved to inhibit Justices Leonen and Caguioa for alleged bias due to his political ties and past criticisms.
    • Detailed a related criminal complaint by Robles (qualified Safe Spaces Act violation, cyber libel, libel) and claimed provocation by Robles’s tweets regarding alleged tax evasion by BBM.
    • Stated that the video was private, intended only for Robles, and argued his expletives were expressions of passion, not gender-based harassment.

Issues:

  • Disbarment
    • Whether Atty. Gadon should be disbarred for conduct unbecoming of a lawyer and violations of the CPRA and Safe Spaces Act.
  • Additional issues
    • Legality and timing of the preventive suspension.
    • Validity of the motion to inhibit Justices Leonen and Caguioa.
    • Applicability of gender-based online sexual harassment provisions.
    • Whether his accusations against the justices constituted direct contempt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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