261. SEA LION FISHING v. PEOPLE G.R. No.

172678 | 23 March 2011

DOCTRINE: The trial court cannot consider evidence which has not been formally offered.

Sec. 34, Rule 132 of the Rules of Court, evidence not formally offered cannot be
considered by the court. In this case, the certificate of registration has not been formally offered.
Therefore, it cannot be considered by the court so as to rule that Sea Lion Fishing is the owner of
F/V Sea Lion.

262.Venus B. Castillo, et. Al., and Prudential Plans, Inc. Employees Union – Federation of Free
Workers (PPEU – FFW) v. Prudent Life Plans, Inc. G.R. No. 196142 | 26 March 2014

DOCTRINE: It is an established rule that the jurisdiction of the Supreme Court (SC) in cases
brought before it from the Court of Appeals (CA) via Rule 45 of the 1997 Rules of Civil Procedure
is generally limited to reviewing errors of law; There are, however, recognized exceptions to this
rule such as when there is a divergence between the findings of facts of the National Labor
Relations Commission (NLRC) and that of the Court of Appeals.

When there is a divergence between the findings of facts of the labor tribunals and the
CA, there is a need to refer to the record. “It is an established rule that the jurisdiction of the
Supreme Court in cases brought before it from the CA via Rule 45 of the1997 Rules of Civil
Procedure is generally limited to reviewing errors of law. This Court is not a trier of facts. In the
exercise of its power of review, the findings of fact of the CA are conclusive and binding and
consequently, it is not our function to analyze or weigh evidence all over again. There are,
however, recognized exceptions to this rule such as when there is a divergence between the
findings of facts of the NLRC and that of the CA.”

263. Victor Rondina v. People of the Philippines G.R. No. 179059 | 13 June 2012

DOCTRINE: At the core of almost all rape cases, the credibility of the victim’s testimony is crucial
in view of the intrinsic nature of the crime where only the participants therein can testify to its
occurrence.

The Court had consistently acknowledged that “[a]t the core of almost all rape cases, the
credibility of the victim’s testimony is crucial in view of the intrinsic nature of the crime where
only the participants therein can testify to its occurrence.” Hence, “the testimony of the
complainant must be examined with extreme care for, whether the case results in conviction or
in acquittal, the final outcome would almost invariably be dependent on what the victim declares
and on how she has stood and comported herself at the witness stand during questioning.”
264. FABIE v. REAL A.C. No. 10574 | 20 September 2016

DOCTRINE: When the integrity of a member of the bar is challenged, he must show proof that he
still maintains that degree of morality and integrity which at all times is expected of him

“The Court has emphatically stated that when the integrity of a member of the bar is
challenged, it is not enough that [he] denies the charges against him; [he] must meet the issue
and overcome the evidence against [him]. [He] must show proof that [he] still maintains that
degree of morality and integrity which at all times is expected of [him]."

265. ANACTA v. RESURRECCION A.C. No. 9074 |14 August 2012

DOCTRINE: One of the qualifications required of a candidate for admission to the bar is the
possession of good moral character

One of the qualifications required of a candidate for admission to the bar is the possession
of good moral character, and, when one who has already been admitted to the bar clearly shows,
by a series of acts, that he does not follow such moral principles as should govern the conduct of
an upright person, and that, in his dealings with his clients and with the courts, he disregards the
rule of professional ethics required to be observed by every attorney, it is the duty of the court,
as guardian of the interests of society, as well as of the preservation of the ideal standard of
professional conduct, to make use of its powers to deprive him of his professional attributes
which he so unworthily abused.

The court is vested with the authority to impose suspension in any of the following
circumstances: (1) deceit; (2) malpractice; (3) gross misconduct; (4) grossly immoral conduct; (5)
conviction of a crime involving moral turpitude; (6) violation of the lawyers oath; (7) wilful
disobedience of any lawful order of a superior court; or (8) corruptly or wilfully appearing as an
attorney for a party to a case without authority to do so.

Rule 1.01 of the Code of Professional Responsibility states that "a lawyer shall not engage
in unlawful, dishonest, immoral or deceitful conduct." "The Code exacts from lawyers not only a
firm respect for law, legal processes but also mandates the utmost degree of fidelity and good
faith in dealing with clients and the moneys entrusted to them pursuant to their fiduciary
relationship."

266. ANDRES V. NAMBI A.C. No. 7158 | 9 March 2015

DOCTRINE: For there to be gross ignorance of the law, the error must be moved with malice, bad
faith, corruption, fraud and dishonesty.

As a rule, for one to be held administratively accountable for gross ignorance of the law,
there must be a showing that the error was gross and patent as to support a conclusion that the
actor was so moved with malice, bad faith, corruption, fraud, and dishonesty.
267. GABRIEL v. RAMOS A.M. No. P-06-2256| 10 April 2013

DOCTRINE: We require nothing less than the highest standard of morality and decency for each
and every member, from the highest official to the lowest of the rank and file, to preserve the
good name and integrity of courts of justice.

Immorality has been defined to include not only sexual matters but also “conducts
inconsistent with rectitude, or indicative of corruption, indecency, depravity, and dissoluteness;
or is willful, flagrant or shameless conduct showing moral indifference to opinions of respectable
members of the community, and an inconsiderate attitude toward good order and public
welfare.”

The illicit relationship between a married man and a woman who is not his wife remains illicit –
the number of years doesn’t matter. These acts put in question his sense of morality, or the
standard of morality he lives by. An officer of the court, and any employee thereof for that
matter, should be above reproach. The very existence of the court, the institution we represent,
is anchored on upholding what is true, right and just. That is why we require nothing less than
the highest standard of morality and decency for each and every member, from the highest
official to the lowest of the rank and file, to preserve the good name and integrity of courts of
justice, lest we be deemed unworthy to represent this honorable institution.

268. PLAZA v. AMAMIO A.M. No. P-08-2559 | 19 March 2010

DOCTRINE: The court and its premises shall be used exclusively for court or judicial functions and
not for any other purpose. As temples of justice, their dignity and sanctity must be preserved at
all times.

In Administrative Circular No. 3-92, we have already reminded all judges and court
personnel that "the Halls of Justice may be used only for purposes directly related to the
functioning and operation of the courts of justice, and may not be devoted to any other use The
Argao Hall of Justice is not meant to be used for festivities, and in fact should remain closed to
the public during such occasions.

Time and again, the Court has always stressed in pertinent issuances and decisions that courts
are temples of justice, the honor and dignity of which must be upheld and that their use shall not
expose judicial records to danger of loss or damage. So strict is the Court about this that it has
declared that the prohibition against the use of Halls of Justice for purposes other than that for
which they have been built extends to their immediate vicinity including their grounds. If the
building housing the Argao Hall of Justice is such an important historical landmark, all the more
reason why activities, such as Sara Lee raffle draw, should not be held within. At most, the said
Hall of Justice could have been made part of a regular local tour, to be viewed at designated
hours, which viewing shall be confined to certain areas not intrusive to court operations and
records.
269. DAVAO IMPORT DISTRIBUTORS v. LANDERO A.C. No. 5116 | 13 April 2015

DOCTRINE: An attorney is bound to protect his client's interest to the best of his ability and with
utmost diligence

As an officer of the court and its indispensable partner in the sacred task of administering
justice, graver responsibility is imposed upon a lawyer than any other to uphold the integrity of
the courts and to show respect to its processes. Any act on his part which tends visibly to obstruct,
pervert or impede and degrade the administration of justice constitutes professional misconduct
calling for the exercise of disciplinary action against him.

270. CAOILE v. MACARAEG AC No. 720 | 17 June 2015

DOCTRINE: A motion for extension to file an appellant’s brief carries with it the presumption that
the applicant-lawyer will file the pleading within the requested extended period. Failure to do so
without any reasonable excuse violates the Code of Professional Responsibility.

The Code of Professional Responsibility allows a counsel to withdraw his services for a
good cause, including the client’s failure to comply with the retainer agreement.

● A motion for extension to file an appellant’s brief carries with it the presumption that the
applicant-lawyer will file the pleading within the requested extended period. Failure to do so
without any reasonable excuse violates the Code of Professional Responsibility.
● The court, however, dismissed the petitioner’s complaint for disbarment because the
complainant had already lost interest in pursuing this disbarment case against Atty. Macaraeg
and that there is truth in the handwritten notation in the return of the subpoena that Atty.
Macaraeg had already passed away.

271. SALABAO v. VILLARUEL A.C. No. 8084 | 24 August 2015

DOCTRINE: While it is true that lawyers owe "entire devotion" to the cause of their clients, it
cannot be emphasized enough that their first and primary duty is "not to the client but to the
administration of justice."

A lawyer’s first and primary duty is not to the client but to the administration of justice.
Canon 12 of the Code of Professional Responsibility states that "A lawyer shall exert every effort
and consider it his duty to assist in the speedy and efficient administration of justice." Thus, in
the use of Court processes, the lawyer's zeal to win must be tempered by the paramount
consideration that justice be done to all parties involved, and the lawyer for the losing party
should not stand in the way of the execution of a valid judgment. Because a lawyer is an officer
of the court called upon to assist in the administration of justice, any act of a lawyer that
obstructs, perverts, or impedes the administration of justice constitutes misconduct and justifies
disciplinary action against him.
272. AC No. 9395 | 12 November 2014

DOCTRINE: A lawyer cannot invoke, as a defense, good faith and/or non-use of information given
by the client in a disbarment case for conflicting interest.

Rule 15.03 of Canon 15 of the CPR. (Rule 15.03 – A lawyer shall not represent conflicting
interests except by written consent of all concerned given after a full disclosure of the facts.)

A lawyer may not act as counsel for a person whose interest conflicts with that of his present or
former client. The prohibition against representing conflicting interests is absolute and the rule
applies even if the lawyer has acted in good faith and with no intention to represent conflicting
interests. A lawyer may not act as counsel for a person whose interest conflicts with that of his
present or former client. The prohibition against representing conflicting interests is absolute
and the rule applies even if the lawyer has acted in good faith and with no intention to represent
conflicting interests. a lawyer who takes up the cause of the adversary of the party who has
engaged the services of his law firm brings the law profession into public disrepute and suspicion
and undermines the integrity of justice. Indeed, Atty. Davis could have simply advised both
complainant and Balageo to instead engage the services of another lawyer.

273. CAMPOS v. ESTEBAL AC No. 10443 | 8 August 2016

DOCTRINE: Atty. Estebal’s act of receiving such substantial sums from complainants without in
the least intending to honor his word to secure the United States (U.S.) tourist visas that he
promised to get for them constitutes a breach of his professional responsibility.

CANON 15 - A LAWYER SHALL OBSERVE CANDOR, FAIRNESS AND LOYALTY IN ALL HIS
DEALINGS AND TRANSACTIONS WITH HIS CLIENTS

Canon 16, Rule 16.01 because he did not account [for] the money he received from the
complainants, because of this, it became unclear to the complainants how much is the amount
due to the respondent.