Case Digest (G.R. No. 68635) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In A.M. No. 23-05-05-SC, decided en banc on July 11, 2023, the Public Attorney’s Office (PAO), through its Chief, Atty. Persida V. Rueda-Acosta, wrote two letters to Chief Justice Alexander G. Gesmundo dated April 20 and June 6, 2023. In these communications, Atty. Acosta sought (1) the deletion of Section 22, Canon III of the newly promulgated Code of Professional Responsibility and Accountability (CPRA)—which addresses conflict of interest for PAO lawyers—and (2) a temporary suspension of its implementation pending a Supreme Court En Banc review of its constitutionality, integrity-of-justice impact, and safety implications for PAO counsel. She argued that this provision unfairly distinguishes indigent clients of the PAO from paying clients of private law firms and allegedly conflicts with the PAO’s charter under Executive Order No. 292, as amended by Republic Act No. 9406, and with the PAO’s 2021 Revised Operations Manual. The Court noted that these objections essentially r Case Digest (G.R. No. 68635) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Atty. Acosta’s communications
- On April 20, 2023, Atty. Persida V. Rueda-Acosta, Chief of the PAO, wrote to Chief Justice Gesmundo requesting:
- Deletion of Section 22, Canon III of the proposed Code of Professional Responsibility and Accountability (CPRA).
- Temporary suspension of its implementation pending review of constitutionality and impact on justice system integrity and public attorneys’ safety.
- On June 6, 2023, she reiterated her concerns and sought a dialogue, reiterating comments from her September 15, 2022 letter on the CPRA.
- SC’s CPRA promulgation process
- The Supreme Court en banc conducted extensive consultations across five major cities over five months, collating comments from stakeholders, including the PAO.
- The CPRA was approved on April 11, 2023, published in the Philippine Star and Manila Bulletin on May 14, 2023, and took effect on May 30, 2023.
- Content of Section 22, Canon III (CPRA)
- Declares the PAO as the government’s primary legal aid service and mandates avoidance of conflicts that leave marginalized parties unassisted.
- Provides that a conflict of interest of any PAO lawyer is imputed only to that lawyer and the lawyer’s direct supervisor, allowing other PAO lawyers to represent the client upon full disclosure and written informed consent.
Issues:
- Requests by the PAO Chief
- Should Section 22, Canon III of the CPRA be deleted entirely?
- Should its implementation be temporarily suspended pending further review?
- Constitutional and statutory questions
- Did the Supreme Court exceed its rule-making power under Art. VIII, Sec. 5(5) by promulgating Section 22?
- Does Section 22 violate the equal protection clause by distinguishing indigent clients?
- Is Section 22 inconsistent or repugnant with Republic Act No. 9406 (PAO Charter) or the 2021 Revised PAO Operations Manual?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)