Case Summary (A.C. No. 10204)
Antecedents
On September 9, 2013, Atty. Lazo delivered a speech during a session of the Sangguniang Panlalawigan, where he accused Judge Ramos of accepting a bribe of PHP 2,000,000.00 in exchange for the acquittal of the accused in Criminal Case Nos. 2131-2131-19. He called for her to inhibit herself from the case and requested the Sangguniang Panlalawigan to monitor the proceedings closely. Subsequently, on September 16, 2013, Atty. Lazo again insinuated misconduct related to Judge Ramos in another criminal case, alleging a personal bias in favor of a relative of an acquitted accused. Both speeches received media coverage.
Provincial and Administrative Actions
The Sangguniang Panlalawigan passed a resolution urging an investigation into Judge Ramos's conduct. However, the complaint submitted for this purpose was returned for lacking compliance with the required form. Subsequently, on December 9, 2013, Atty. Lazo filed an administrative complaint against Judge Ramos, registered as OCA IPI No. 13-4177-RTJ. In response, on October 3, 2013, Judge Ramos filed a Verified Disbarment Complaint against Atty. Lazo, citing violations of several rules under the Code of Professional Responsibility, penalizing slanderous remarks against her character.
IBP Report and Recommendation
On July 15, 2016, the Integrated Bar of the Philippines (IBP) Commissioner, Peter M. Bantilan, recommended a one-year suspension for Atty. Lazo due to his malice and bad faith in delivering his speeches, which undermined the integrity of the RTC, reflecting poorly on the justice system. The report emphasized that concerns about judicial conduct should be raised through proper channels rather than through public statements that could damage the image of the judiciary.
IBP Board of Governors Resolution
On May 27, 2017, the IBP Board of Governors reversed the Commissioner's recommendation, dismissing the complaint against Atty. Lazo. They cited his right to deliver a privileged speech as a member of the Sangguniang Panlalawigan, asserting that the nature of his comments did not breach the Code of Professional Responsibility since he addressed the issues within the context of a public session.
Issue
The central issue was whether Atty. Lazo could be held administratively liable for violations of the Code of Professional Responsibility related to his public statements about Judge Ramos.
Ruling of the Court
The Court found Atty. Lazo administratively liable for violations of the Code of Professional Responsibility. It reaffirmed the sacred responsibility of lawyers to uphold the integrity and respect for the courts and judicial officers. The Court delineated that while lawyers have the right to criticize judicial conduct, such criticisms must be done within the bounds of respect and decorum, refraining from baseless allegations that can erode public confidence in the judiciary.
Legal Standards
The ruling underscored that all lawyers are expected to uphold the rule of law and maintain the respect due to the courts and judicial officers. Canon 1 prohibits actions that defy the law or diminish public confidence in legal institutions. Furthermore, the Court highlighted specific rules prohibiting lawyers from making public statements that could incite bias against a party in a pending case or attributing motives to judges that are not backed by evidence.
...continue readingCase Syllabus (A.C. No. 10204)
Background of the Case
- This case involves a Verified Disbarment Complaint filed by Judge Rosemarie V. Ramos against Atty. Vicentito M. Lazo for alleged violations of the Code of Professional Responsibility.
- The complaint arose from speeches made by Atty. Lazo during sessions of the Sangguniang Panlalawigan of Ilocos Norte, where he accused Judge Ramos of corruption and bias in specific criminal cases.
Antecedents of the Case
- On September 9, 2013, Atty. Lazo, during a session of the Sangguniang Panlalawigan, claimed that Judge Ramos had received P2,000,000 for the acquittal of four accused individuals in Criminal Case Nos. 2131-2131-19.
- He urged Judge Ramos to inhibit from the case and called for monitoring to prevent bribery.
- On September 16, 2013, he made further allegations regarding Judge Ramos's conduct in Criminal Case No. 1962 for illegal sale of dangerous drugs, suggesting that her decisions were influenced by personal bias.
- Atty. Lazo's statements were made in the presence of the media, which amplified their impact.
Procedural Developments
- Following Atty. Lazo's public accusations, the Sangguniang Panlalawigan passed a resolution urging the Supreme Court to investigate Judge Ramos's competence and moral fitness.
- Judge Ramos subsequently filed her Verified Disbarment Complaint on October 3, 2013.
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