A.C. No. 10204 - Ramos vs. Lazo

Atty. Vicentito M. Lazo, a member of the Sangguniang Panlalawigan of Ilocos Norte, delivered speeches before the Sangguniang Panlalawigan on two separate occasions in September 2013.
In his speech on September 9, 2013, he discussed Criminal Case Nos. 2131-2131-19 pending before RTC, Branch 19, Bangui, Ilocos Norte, alleging that Judge Rosemarie V. Ramos had issued an Order of Inhibition after receiving a report that she obtained P2,000,000.00 in exchange for acquitting the accused. He further urged her inhibition and cautioned the Sangguniang Panlalawigan to monitor the case closely to prevent any undue influence or “money changing hands.”
On September 16, 2013, during another speech, Atty. Lazo referred to Criminal Case No. 1962 for illegal sale of dangerous drugs and insinuated irregularities in the case resolution, hinting at personal bias on the part of Judge Ramos. He insinuated that the wrongful acquittal resulted from her personal relationship with a relative of the accused, even mentioning rumors about her “sala” as a venue for justice-for-sale.

Judge Ramos, in response, filed a Verified Disbarment Complaint/Letter Affidavit (with an urgent prayer for an injunction/gag order) dated October 3, 2013 against Atty. Lazo, alleging that he violated several provisions of the Code of Professional Responsibility including Canon 1, Rule 1.02; Canon 11, Rules 11.04 and 11.05; and Canon 13, Rule 13.02.
Atty. Lazo, allegedly acting in his personal capacity, later submitted an administrative complaint against Judge Ramos on December 9, 2013, which was docketed as OCA IPI No. 13-4177-RTJ.
Simultaneously, the Sangguniang Panlalawigan had passed Provincial Resolution No. 011-2013 urging the Supreme Court to investigate Judge Ramos’ moral fitness and judicial competence. However, this complaint was later returned for failing to meet the required formality.

On July 15, 2016, IBP Commissioner Peter M. Bantilan issued a Report and Recommendation finding Atty. Lazo liable for violating the Code, recommending his suspension from the practice of law for one year. The Commissioner held that Atty. Lazo’s conduct, marked by bad faith and malice, destroyed the integrity of the RTC and undermined public confidence in the judicial system.
On May 27, 2017, the IBP Board of Governors passed a Resolution to dismiss the complaint and reverse the recommendations of the Investigating Commissioner by directing an extended explanation regarding their action.
In the Extended Resolution dated June 23, 2019, the Board clarified that as a member of the Sangguniang Panlalawigan, Atty. Lazo was entitled to a privileged speech under constitutional and procedural safeguards. Nonetheless, they maintained that his delivery did not warrant a finding of misconduct under the Code of Professional Responsibility.

Atty. Lazo publicly leveled serious allegations against Judge Ramos, accusing her of bribery, corruption, bias, and immorality, thereby maligning her personal character as well as the integrity of her judicial office.
His statements, made in the presence of the media during public sessions, resulted in the rapid spread of rumors and engendered public distrust in the judicial system.
Despite his later filing of a complaint against the judge through the proper channel (i.e., the OCA), his public statements were deemed to have exceeded the acceptable limits of free speech for a lawyer in his official capacity.

The Regional Trial Court, Branch 19 in Bangui, Ilocos Norte ultimately resolved the case by finding Atty. Lazo administratively liable for his actions.
The Court’s decision to impose a one-year suspension was based on the finding that his statements were unsubstantiated, malicious, and violated several specific provisions of the Code of Professional Responsibility.

Whether Atty. Lazo’s public statements and speeches, particularly the unverified accusations against Judge Ramos, constitute a violation of the Code of Professional Responsibility.

Did his actions amount to an affront against the duty of respect and fidelity owed by a lawyer to the courts and its judicial officers?
Were his public utterances, made in the presence of the media, a proper exercise of his right to criticize, or did they transgress acceptable bounds by maligning a sitting judge without due process?

Whether the proper procedures for airing grievances against a judge were ignored, leading to an exacerbation of public defamation and erosion of confidence in the judicial system.

Can a lawyer’s privileged speech before a legislative body justify making unsubstantiated personal attacks against a judge?
Did Atty. Lazo bypass the appropriate administrative channels (i.e., filing a complaint with the OCA) in favor of public denunciation?