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 chargefrom the refusal of the law firm to divulge informations 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 amedned 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 thesaid PCGG case.The law firm
petitioned for the PCGG to grant them the same treatment as what had been accorded to Roco. It wasonly 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 clients2) Submission of documents purporting to the substantiation of the lawyer-client
relationship3) 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 1 st 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
thelayer
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
clientseeks 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.