Title
Palad vs. Solis
Case
G.R. No. 206691
Decision Date
Oct 3, 2016
Atty. Palad’s suspension, linked to a high-profile case, was published by journalists. SC ruled no confidentiality breach or contempt, citing public interest and press freedom.

Case Digest (A.M. No. MTJ-04-1564)
Expanded Legal Reasoning Model

Facts:

  • Administrative proceedings
    • On December 14, 2012, the Integrated Bar of the Philippines (IBP) Board of Governors issued a Resolution in CBD Case No. 09-2498 recommending a one-year suspension of Atty. Raymund P. Palad for alleged violations of the Code of Professional Responsibility.
    • Petitioner received the Resolution on March 8, 2013, and promptly filed a Motion for Reconsideration.
  • Media publications of the pending suspension
    • On April 23, 2013, Lolit Solis published in Filipino Star Ngayon’s “Take it, Take it” column an article reporting that Palad had already been suspended for one year, including commentary on his alleged failure to verify reports against Belo Medical Clinic.
    • That same day, Ricardo F. Lo wrote in his Funfare column in The Philippine Star about Palad’s purported suspension, citing unnamed Funfare sources and noting Palad’s pending motion for reconsideration.
  • Petitioner’s contempt petition and respondents’ defenses
    • Petitioner charged respondents Solis, Salve V. Asis (editor), Al G. Pedroche (Editor-in-Chief), and Lo with indirect contempt for violating the confidentiality rule under Section 18, Rule 139-B of the Rules of Court by disclosing a pending disciplinary proceeding.
    • Respondents maintained they are long-time entertainment journalists who wrote on information from reliable sources; they argued the story involved a public figure and a matter of public interest, meriting qualified privilege, and libel charges against them were previously dismissed for lack of malice.

Issues:

  • Did respondents violate Section 18, Rule 139-B of the Rules of Court, which mandates confidentiality of attorney disciplinary proceedings, thereby committing indirect contempt?
  • Did respondents breach the Supreme Court’s ruling in Fortun v. Freedom Fund for Filipino Journalists by publishing the pending administrative complaint against petitioner?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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