VIII.

NATURE & CREATION OF ATTY-CLIENTRELATIONSHIP

REGALA VS SANDIGANBAYAN

FACTS:
Raul Roco and his colleagues from the ACCRA Law Office were charged together with Eduardo
Cojuangco for acquiring ill-gotten wealth. The PCGG based its charge from the refusal of the law
firm to divulge information as to who had been involved in PCGG Case No. 0033, despite the
nature of the services performed by AACRA (e.g. The law firm knows the assets, personal
transactions, & business dealings of their clients).Later, the PCGG amended the complaint, resulting
in the exclusion of Roco from the list of defendants. Such exclusion was based from the
manifestation of Roco that he would identify the persons & stockholders involved in the said
PCGG case. The law firm petitioned for the PCGG to grant them the same treatment as what had
been accorded to Roco. It was only at this point that the PCGG answered with a “set
of requirements and conditions for exclusion” which were:1) disclosure of the identity of the clients
2) Submission of documents purporting to the substantiation of the lawyer-client relationship
3) Presentation of the deeds of assignments which the lawyers executed in favor of its clients,
covering the shareholdings of the latter To bolster this set-up, the PCGG presented supposed
proof to the effect that Roco had complied with such conditions. The 1st Division of SB denied the
petition of ACCRA.

ISSUE:
W/N SB did not uphold the sanctity of the lawyer-client relationship.

HELD:
As a general rule, the identity of the client should not be shrouded with mystery, as a requirement of
due process, EXCEPT when: A) revealing the name of a client would implicate the latter in the very
activity for which he sought the advice of the layer B) The disclosure would expose the client to civil
liability C) The content of the client communication is relevant to the subject matter of the legal
problem on which the client seeks legal assistance. The case of the prosecution must be built upon
evidence gathered by them from their own sources, not from compelled testimony requiring them to
reveal information prejudicial to their client. The confidentiality privilege extends even after the
termination of the lawyer-client relationship