Title
IN RE: Inquiry into the 1989 Elections of the Integrated Bar of the Philippines
Case
B.M. No. 491
Decision Date
Oct 6, 1989
The 1989 IBP elections were annulled due to widespread violations, including vote-buying, overspending, and misuse of government resources, prompting Supreme Court intervention and reforms.

Case Summary (B.M. No. 491)

Petitioner / Respondent / Procedural Posture

The matter was an inquiry by the Supreme Court en banc into alleged irregularities attending the June 3, 1989 IBP national elections. The Court exercised its supervisory power over the Integrated Bar of the Philippines (IBP), suspended the scheduled oath-taking of the proclaimed officers, convened an informal dialogue, then appointed an investigative committee and conducted formal hearings with subpoenas. The committee reported to the Court, and the Court adopted the report and promulgated a resolution ordering relief and structural changes to IBP governance.

Key Dates

Key event dates appearing in the record: IBP national election and canvass — June 3, 1989; suspension of oath-taking and initial en banc resolution calling for appearances — mid-June 1989 (resolution dated June 15, 1989); informal dialogue and subsequent formation of investigative committee — June 1989; hearings with witnesses and documentary submissions — June–July 1989; the Court’s resolution adopting the committee’s report and ordering relief — promulgated by the Court and reflected in the record (decision/per curiam).

Applicable Law and Institutional Framework

Primary governing instrument referenced and applied: the IBP By-Laws (notably Article I, Section 4 — Non-political Bar; Section 14 — Prohibited acts and practices relative to elections; Section 12(d) — sanctions for violations). The Court also considered the institutional context created by the 1987 Constitution (reference made in the opinion to Section 8, Article VIII concerning the Judicial and Bar Council and the role of an IBP representative), and the Code of Professional Responsibility (Canon 1, Rule 1.02) insofar as professional ethics and lawyers’ duties were concerned. The Supreme Court relied on its supervisory authority over the IBP, including powers to amend, modify or repeal IBP By-Laws under Section 77, Article XI of those By-Laws.

Background Facts of the Election and Immediate Reactions

On June 3, 1989, a House of Delegates composed of 120 chapter presidents (or alternates) voted for national IBP officers; a slate headed by Atty. Violeta Drilon was proclaimed. Widespread media reports and complaints alleged intensive electioneering, lavish expenditures, vote-buying, use of government aircraft, and the intervention of public officials — activities said to violate IBP’s non-political rules. Although the mechanical conduct of voting and canvassing (supervised by the IBP Comelec under Justice Puno) was generally regarded as aboveboard, the Court was disturbed by allegations about pre- and post-election campaigning and inducements.

Media Allegations and Their Content

Several newspaper columnists published critical accounts alleging vote-buying, extravagant hospitality (billeting delegates in five-star hotels with food, drink, entertainment), use of PNB helicopters/planes, offers of government positions, and active campaigning by DOLE personnel and other public officials. Allegations included monetary offers for votes (reported ranges and claims), distribution of campaign materials, and the existence of campaign “war rooms” at hotels. Columnists refused to identify confidential sources; the Court nonetheless subpoenaed them to test the sources and veracity of the reports.

Supreme Court’s Initial Response and Inquiry Process

The Supreme Court en banc suspended the scheduled oath-taking of the proclaimed officers and directed senior IBP officials and chapter representatives to appear and address the reported improprieties. After an informal meeting, the Court created a formal fact-finding committee chaired by Senior Associate Justice Narvasa. The committee issued subpoenas, took testimony from 49 witnesses (including candidates, campaign managers, hotel and airline officials, government department personnel, and media columnists), and received documentary evidence (hotel and airline records, PNB manifests, nomination forms, hotel contracts, receipts, and campaign materials). The committee prepared a report which the Court reviewed and adopted.

Relevant IBP By-Laws and Specific Prohibited Conduct

The Court relied on explicit IBP By-Laws provisions:

  • Section 4 (Article I) — declares the IBP “strictly non-political” and prohibits campaigning by government officeholders while in office.
  • Section 14 — lists prohibited election practices: distribution (except limited biodata) of campaign materials, campaigning while holding government office, formation of slates or tickets, payment of dues or giving food, drink, entertainment, transportation or any item of value to induce voting, and promises or expenditures made to influence votes.
  • Section 12(d) — provides disqualification or removal and other sanctions for violations. The inquiry assessed whether the acts alleged fell within these prohibitions.

Findings: Prohibited Campaigning and Solicitation

The committee found that the three principal presidential candidates (Drilon, Nisce, Paculdo) engaged in nationwide campaigning beginning months before the election, soliciting votes from chapter presidents and delegates, attending Bench-and-Bar dialogues and chapter meetings to announce candidacies, carrying nomination forms to secure written commitments, and reserving hotel rooms and facilities for supporters and delegates. Several candidates admitted to seeking commitments and making travel and lodging arrangements for delegates.

Findings: Use of Government Plane and Travel Benefits

Documentary evidence (PNB manifests) and witness testimony established that Atty. Drilon “hitched” a ride on a PNB plane that was primarily arranged for DENR official travel; the manifest named several IBP candidates among the passengers. Testimony from Atty. Arturo Tiu and Assistant Secretary Antonio Tria corroborated use of that PNB aircraft. There was also testimony and airline records indicating some candidates (notably Nisce) purchased plane tickets for out-of-town delegates; allegations were made about candidates providing free PAL tickets but witnesses often invoked refusal or non-use to avoid commitments.

Findings: Formation of Tickets / Single Slates and Distribution of Campaign Materials

The inquiry established that each of the three camps formed their own tickets/slates and actively promoted them. Candidates distributed biodata and full campaign literature in contravention of the By-Laws’ restrictions. One candidate (Paculdo) admitted printing campaign materials costing P15,000–P20,000 and employing uniformed girls and other persons to distribute materials on the convention floor; others similarly distributed lists of slates and biodata.

Findings: Provision of Free Accommodation, Food, Entertainment and Other Inducements

Extensive hotel bookings and expenditures were documented:

  • Paculdo: reservations and payments at Holiday Inn (evidence of 52 rooms and total payments of P227,114.89; Paculdo acknowledged spending about P250,000 on campaign trips and hospitality).
  • Drilon: Philippine Plaza bookings coordinated by campaign manager Callanta (40 rooms including suites; Callanta paid P316,411.53 but left a large unpaid balance; receipts and a working sheet document significant contributions from law firms and individuals).
  • Nisce: Hyatt reservations and bills totaling P216,127.74; downpayments documented. Witnesses testified to “war rooms” where strategy and support were coordinated; DOLE officials (Assistant Secretary Benedicto) stayed in suites adjacent to Drilon’s group and provided moral support and tactical discussions. The committee found evidence that hotel accommodations, food, and related hospitality were used as part of exerting influence.

Findings: Campaigning by Government Officials and Fraternal/Professional Influence

Testimony showed active political support from government employees (DOLE officials and labor arbiters) and prominent lawyers/firm affiliations. Assistant Secretary Benedicto (DOLE) admitted he took leave to attend the convention and stayed with Drilon’s group; he and others (including members of Sigma Rho fraternity and lawyers from specific law firms) were implicated in assisting Drilon’s campaign. The committee found this contravened the by-law prohibition on campaigning by government officeholders.

Findings: Inducements, Vote Manipulation, and Payments of Dues

The committee received evidence and testimony suggesting inducements, attempts to induce delegates (including offers of jobs, assistance with dues, or pre-paid travel and accommodation) and instances of delegates changing commitments. The IBP Treasurer observed spikes in dues payments in election months but could not trace payors because receipts were issued in members’ names; nonetheless, the timing and volume of payments suggested a pattern consistent with election-year inducements. Some witnesses alleged explicit offers (e.g., offers of judgeships) though some of these statements were hearsay or denied by the persons alleged to have made offers.

Findings: Dishonesty and Evasion in Testimony

The Court noted evasions, denials and prevarications by witnesses and some candidates during initial hearings; the committee’s subsequent, more thorough investigation revealed inconsistencies and conduct indicating attempts to conceal irregularities. The Court regarded these evasions as aggravating the misconduct and as undermining candor owed to the Court and the profession.

Campaign Expense Totals Documented

The inquiry produced concrete figures:

  • Paculdo: admitted campaign expenditures roughly P250,000 (including hotel bills and provincial travel).
  • Nisce: hotel bills at the Hyatt amounted to P216,127.74 plus additional campaign travel and ticket purchases.
  • Drilon: Philippine Plaza records showed over P600,000 in hotel-related charges tied to her camp, with Callanta’s paid sum and outstanding balances documented (Callanta paid P316,411.53 and left an unpaid balance of over P300,000 at the time of inquiry).

Legal and Ethical Conclusio

    ...continue reading

    Analyze Cases Smarter, Faster
    Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.

    About Privacy Terms