Case Digest (A.C. No. 9923)
Facts:
In the Matter of the Petition to Cite Respondent Atty. Lorna Patajo-Kapunan for Indirect Contempt of Court, A.C. No. 9923, October 09, 2019, the Supreme Court Second Division, Lazaro-Javier, J., writing for the Court. Petitioner Atty. Raymund P. Palad filed an original petition asking the Court to cite respondent Atty. Lorna Patajo-Kapunan for indirect contempt for allegedly violating the confidentiality rule in disciplinary proceedings under Section 18, Rule 139‑B of the Rules of Court by publicly stating on a live radio interview that a lawyer (which petitioner says meant him) "has been suspended by the Supreme Court."The antecedent events began with the Integrated Bar of the Philippines (IBP) Board of Governors’ Resolution dated December 14, 2012 in CBD Case No. 09‑2498 recommending petitioner’s suspension; petitioner thereafter filed a motion for reconsideration. On April 23, 2013, an entertainment news article in Pilipino Star Ngayon reported petitioner’s alleged one‑year suspension and petitioner sought investigation into the premature release of information. On May 8, 2013, a DZMM Teleradyo live phone‑patch interview with Noli de Castro featured Atty. Patajo‑Kapunan, who stated in response to questions about RA 9995 and RA 10175 that “the lawyer of Katrina has been suspended by the Supreme Court.” Petitioner secured an audio transcript of that interview and then filed the present petition alleging violation of confidentiality and seeking contempt sanctions.
Respondent Atty. Patajo‑Kapunan denied malice, contending she did not name petitioner, relied on circulating media reports (including the April 23 article), believed the report to be accurate, was speaking spontaneously in a live interview about public issues (RA 9995/RA 10175), and had delegated handling of the IBP administrative matter to colleagues. Petitioner replied that, as lead counsel in related matters, respondent knew of t...(Subscriber-Only)
Issues:
- Should Atty. Patajo‑Kapunan be held liable for indirect contempt of court for violating Section 18, Rule 139‑B of the Rules of Court by publicly disclosing an allegedly confidential disciplinary de...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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