Case Digest (A.C. No. 13521)
Facts:
In re: Atty. Lorenzo G. Gadon's Viral Video Against Raissa Robles, A.C. No. 13521, June 27, 2023, the Supreme Court En Banc, Per Curiam. The Court initiated this administrative proceeding under Section 27, Rule 138 of the Rules of Court after a video of Atty. Lorenzo G. Gadon verbally assaulting and uttering profanities toward journalist Raissa Robles surfaced and went viral. The Court issued a Resolution dated January 4, 2022 taking cognizance of the clip, quoting Gadon’s profane tirade directed at Robles.The Court’s January 4, 2022 Resolution noted prior incidents demonstrating a pattern of similar misconduct by Gadon (threatening language toward Muslim communities, obscene gestures and insults toward supporters of a former Chief Justice, statements during impeachment proceedings, and malicious imputations against a former president). The Court found the video contravened Rule 7.03 of the then Code of Professional Responsibility (CPR) and constituted prima facie gender-based online sexual harassment under Sections 3(e) and 12 of R.A. No. 11313 (the Safe Spaces Act). The Resolution ordered Gadon to show cause and placed him on preventive suspension effective immediately; it also directed the Office of the Bar Confidant (OBC) and the Integrated Bar of the Philippines (IBP) to submit relevant reports.
In his Comment, Gadon argued the preventive suspension violated due process (citing Section 15, Rule 139-B), denied posting the video (saying it was intended only for Robles), claimed provocation by Robles’s tweets, and insisted his words were aimed at her role as a journalist rather than her gender. He moved for the inhibition of Justices Marvic Leonen and Alfredo Caguioa, alleging bias tied to his political affiliations. Robles filed a criminal complaint in the Quezon City prosecutor’s office charging Gadon with qualified violation of the Safe Spaces Act, cyber libel, and libel. The Court treated the matter as an administrative proceeding sui generis and proceeded en banc to resolve issues of inhibition, preventive suspension, contempt, and professional accountability...(Subscriber-Only)
Issues:
- Should Justices Marvic M. V. F. Leonen and Alfredo B. S. Caguioa be disqualified (inhibit) from participating in this case?
- Was the Court’s immediate preventive suspension of Atty. Gadon proper notwithstanding his complaint about lack of prior answer?
- Should Atty. Lorenzo G. Gadon be disbarred for his conduct in the viral video (and related insinuations against Justices Leonen and Caguioa)?
- Was Atty. Gadon guilty of contempt for his insinuations against members o...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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