Case Digest (B.M. No. 491)
Facts:
On June 3, 1989, at the Philippine International Convention Center (PICC), the House of Delegates of the Integrated Bar of the Philippines (IBP)—composed of 120 chapter presidents or their alternates—elected and proclaimed Atty. Violeta Drilon as President, Atty. Bella Tiro as Executive Vice-President, and other national officers. Their oath-taking, scheduled for July 4, 1989 before the Supreme Court en banc, was suspended after widespread media reports and letters accused the leading presidential candidates—Attys. Drilon, Nereo Paculdo, and Ramon Nisce—of intensive campaign activities in violation of the IBP By-Laws. Alleged irregularities included overspending at five-star hotels, formation of single-slate tickets, distribution of campaign materials beyond election day, provision of free transportation and accommodation to delegates, use of government-owned PNB planes, and officious intervention by Department of Labor officials. Citing its supervisory power over the IBP and t
Case Digest (B.M. No. 491)
Facts:
- Election and Suspension
- On June 3, 1989, the IBP House of Delegates elected national officers at PICC, including Atty. Violeta Drilon as President.
- Scheduled oath-taking on July 4, 1989 was suspended by the Supreme Court en banc due to adverse media reports and allegations of intensive campaign practices in violation of IBP By-Laws.
- Media Reports and Allegations
- Columns by Jurado, Mauricio, and Locsin (June–July 1989) alleged vote-buying, lavish entertaining, use of government planes, and involvement of public officials favoring candidates Drilon, Paculdo, and Nisce.
- Specific charges included PNB helicopter rides for Atty. Drilon, free airfares and hotel accommodations for delegates, and the formation of single-slate tickets.
- Supreme Court Inquiry
- En banc resolution (June 15, 1989) directed IBP officers and chapter presidents to report on the reports’ veracity and recommend reforms to uphold the IBP’s “strictly non-political” character.
- A special committee chaired by Justice Narvasa conducted hearings with 49 witnesses, subpoenaed hotel managers, PNB and ATO officials, Department of Labor officers, and media columnists to gather evidence.
- Established Violations
- Candidates engaged in prohibited campaigning: forming slates, soliciting written commitments, distributing multi-page materials, and using campaign “war rooms” in five-star hotels.
- Use of government-owned PNB aircraft by Drilon’s group; free PAL tickets and hotel accommodations provided by all three camps; employment of uniformed distributors on election day; payment of delegates’ IBP dues.
- Documented campaign expenditures: Paculdo (~₱250,000), Nisce’s Hyatt bill (₱216,127.74), Drilon’s Philippine Plaza charges (over ₱600,000, with an unpaid balance).
- Findings and Conclusions
- The campaign practices violated Section 4 (non-political Bar) and Section 14 (prohibited acts) of the IBP By-Laws.
- The integrity and dignity of the legal profession were undermined by vote-buying, extravagant electioneering, and unethical conduct by lawyers.
- Witnesses and some candidates provided evasive or false testimony, indicating attempts to conceal irregularities.
Issues:
- Election Violations
- Whether the conduct of candidates and supporters contravened the non-political character (Art. I, Sec. 4) and prohibited acts (Sec. 14) of the IBP By-Laws.
- Supervisory Authority
- Whether the Supreme Court, under its supervisory power over the IBP, could annul the June 3 election and prescribe remedies.
- Appropriate Remedies
- What reforms to the IBP By-Laws and election procedures were necessary to restore non-political integrity and prevent recurrence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)