A.C. No. 9298 - Macapagal vs. Young

Case Summary (A.C. No. 9298)

Factual Background and Nature of the Complaint

Before Judge Macapagal took over the case in 2008, a writ of possession was already issued in 2006 by the prior presiding judge. In 2011, Judge Macapagal granted the plaintiffs' motion for demolition, issuing the corresponding writ which was served on October 28, 2011. Atty. Young represented informal settlers who were not parties to the original case. He sent a letter to Judge Macapagal warning her against implementing the writ as it would violate the informal settlers' due process rights. The letter also contained threats of filing administrative and criminal complaints against her for “knowingly rendering an unjust judgment,” which precipitated the complaint for misconduct filed by Judge Macapagal against Atty. Young.

Contents and Tone of Atty. Young’s Letter

The letter addressed Judge Macapagal with repeated reverential phrases but warned that if she proceeded with eviction and demolition against non-parties, administrative and criminal complaints would be filed against her. Atty. Young referenced a parallel case involving allegations of land grabbing and earlier administrative complaints against other judicial officers and sheriffs. He asserted that the writ’s execution against non-parties was a violation of due process rights and requested the judge to cease such actions, emphasizing this as a matter of judicial courtesy and fundamental fairness.

Atty. Young’s Response to the Complaint

Atty. Young submitted a letter-comment and later a formal Comment, denying any intent to malign or threaten. He explained his letter was meant as a courteous warning to protect his clients' due process rights. He justified his actions as part of his duty to diligently and zealously represent his clients within the bounds of the law (referring to Canons 18 and 19 of the CPR). He also claimed the letter prompted Judge Macapagal to reconsider and temporarily halt demolition plans until a temporary restraining order (TRO) was issued. Atty. Young described perceived obstructions in obtaining court records and expressed concerns about administrative misdemeanors, stressing that government officials, including judges, must tolerate oversight and criticism.

Procedural History and Investigation by the Integrated Bar of the Philippines (IBP)

The Court referred the case to the IBP’s Commission on Bar Discipline (CBD) for investigation, report, and recommendation. Mandatory conferences and submissions of position papers followed. While Judge Macapagal chose not to file a position paper, Atty. Young reiterated his defense emphasizing the courteous nature of the letter and the advocacy of his clients’ rights. The Investigating Commissioner initially found Atty. Young guilty of simple misconduct for sending the personal letter to a judge dealing with a pending case, recommending only a warning and reminder against repetition.

IBP Board of Governors’ Final Resolution and Penalty

The IBP Board reversed the initial recommendation and held that Atty. Young’s letter constituted disrespect and was an uncalled-for act against the judiciary, recommending a six-month suspension for violating Canon 11 and Rule 11.04 of the CPR. The Board condemned the “menacing language that imputes ill and corrupt motive to a member of the judiciary” and highlighted the apparent threat in the letter. The Board cited jurisprudence supporting sanctions for lawyers who improperly attempt to influence judicial officers through threats of administrative or criminal complaints, emphasizing the necessity of respect and propriety in lawyer-judge communications.

Atty. Young’s Motion for Reconsideration and Further Proceedings

Atty. Young filed a motion for reconsideration, disputing the gravity of his offense and the penalty imposed. He contended the complaint was unverified, expressed willingness to accept a warning, denied any intention to threaten or malign the judge, claimed that his letter was a legitimate cautionary notice not constituting an unlawful threat, and distinguished the cited cases based on factual differences. He also alleged that his apology was rejected, and he might have been overzealous in defending his clients’ rights. Judge Macapagal refuted his allegations, asserting that he violated Canon 10 for making untruthful statements regarding the apology.

Supreme Court’s Analysis and Final Ruling

The Court found Atty. Young’s letter highly improper, explicitly recognizing the threatening nature of the letter in which he warned of administrative and criminal complaints if the writ of demolition was implemented. Despite Atty. Young’s claim that his intent was to protect due process rights and the judge’s interest in avoiding misconduct, the Court held that his statements lacked the respect required for communications with the judic

Case Syllabus (A.C. No. 9298)

Background and Context of the Case

Presiding Judge Aida Estrella Macapagal (Complaintant), Regional Trial Court (RTC), Branch 195, Parañaque City, filed a letter-complaint on November 10, 2011 against Atty. Walter T. Young (Respondent).
The complaint arose from a letter Atty. Young sent to Judge Macapagal, threatening administrative and criminal complaints for "knowingly rendering an unjust judgment" if a writ of possession/writ of demolition were implemented.
The writ of possession had been issued originally in 2006 and was subsequently renewed or acted upon by Judge Macapagal in connection with a pending expropriation case (Civil Case No. CV-04-0245) filed by the City of Parañaque against Magdiwang Realty Corporation and Fil-Homes Realty Development Corporation.
Judge Macapagal allegedly received the threatening letter from Atty. Young just before implementing the writ related to this pending case, and she alleged his act violated the Code of Professional Responsibility (CPR) constituting an act unbecoming of a lawyer.

Contents and Nature of the Threatening Letter

Atty. Young’s letter dated November 10, 2011, addressed to Judge Macapagal, was respectful in tone but firmly asserted that administrative and criminal complaints would be filed if the writ of possession/demolition were executed against residents (informal settlers) not made parties to the case.
The letter mentioned the filing of a petition for annulment of judgment and injunctive relief with the Court of Appeals (CA-GR-SP No. 121938).
Atty. Young referenced prior experience with the "Torres land grab scam," where an administrative complaint was filed against both the sheriff and presiding judge, drawing a parallel with the present expropriation case.
The letter argued that executing the writ against non-parties violated due process rights and thus threatened an administrative complaint before the Office of the Court Administrator and a criminal complaint for "knowingly rendering an unjust judgment."
The letter included a prayer for Judge Macapagal to cease actions violating due process rights, appealing to judicial courtesy and the honor of the Court of Appeals.

Atty. Young’s Response and Justification

Upon receipt of the complaint, Atty. Young submitted a letter-comment and later a detailed Comment to the Court.
He claimed that his letter was intended as a "courteous warning" to prevent eviction of informal settlers who were not impleaded as parties to the case.
Atty. Young explained that his clients engaged his services just before the planned execution of the writ, and he acted to protect their due process rights.
He denied any intention to malign or threaten the Judge, asserting that the use of cautionary language was meant to prevent possible improper judicial acts.
Atty. Young also highlighted procedural difficulties his clients experienced in obtaining certified court records.
He emphasized that government functionaries, including judges, should not be “onion-skinned” regarding vigilance against possible misconduct or violations of due process.
Atty. Young maintained that the letter merely warned of potential legal consequences stemming from judicial acts affecting non-parties.
He denied disrespect or imputations of corrupt motives but noted the judge may have been "stubbornly pursuing" demolition to please the city mayor.

Proceedings Before the Integrated Bar of the Philippines (IBP)

The case was referred to the IBP-Commission on Bar Discipline (CBD) for investigation, report, and recommendation.
After a mandatory conference and submission of position papers, the Investigating Commissioner found Atty. Young guilty of simple misconduct for sending the letter, recommending only a warning.
The Commissioner noted that the letter was an improper remedy to contest a pending case and that Atty. Young’s intention was immaterial as the act itself was uncalled for.
The IBP Board of Governors reversed the Investi