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Liabilities of Lawyers
Civil Liability
Client is prejudiced by lawyers negligence or misconduct
Breach of fiduciary obligation
Civil liability to third persons
Libelous words in pleadings; violation of communication privilege
Liability for costs of suit (treble costs) when lawyer is made liable for insisting on clients patently
unmeritorious case or interposing appeal merely to delay litigation.

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Criminal Liability
Prejudicing client through malicious breach of professional duty
Revealing clients secrets
Representing adverse interests
Introducing false evidence
Misappropriating clients funds (estafa)

Contempt of Court

a. Kinds of Contempt:
Direct consists of misbehavior in the presence of or so near a court or judge as to interrupt or obstruct
the proceedings before the court or the administration of justice; punished summarily.
Indirect one committed away from the court involving disobedience of or resistance to a lawful writ,
process, order, judgment or command of the court, or tending to belittle, degrade, obstruct, interrupt or
embarrass the court.
Civil- failure to do something ordered by the court which is for the benefit of a party.
Criminal any conduct directed against the authority or dignity of the court.
b. Acts Constituting Contempt:
1. Misbehavior
2. Disobedience
3. Publication concerning pending litigation
4. Publication tending to degrade the court; disrespectful language in pleadings
5. Misleading the court or obstructing justice
6. Unauthorized practice of law
7. Belligerent attitude
8. Unlawful retention of clients funds

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Administrative Liabilities of lawyers


Main Objectives of Disbarment and Suspension:
to compel the attorney to deal fairly and honestly with his clients;
to remove from the profession a person whose misconduct has proved him unfit to be entrusted with the
duties and responsibilities belonging to the office of an attorney;
to punish the lawyer;
to set an example or a warning for the other members of the bar;
to safeguard the administration of justice from incompetent and dishonest lawyers;

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to protect the public

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Characteristics of Disbarment Proceedings:


Neither a civil nor criminal proceedings;
Double jeopardy cannot be availed of in a disbarment proceeding;
It can be initiated motu propio by the SC or IBP. It can be initiated without a complaint;
It is imprescriptible;
Conducted confidentially;
It can proceed regardless of the interest of the lack thereof on the part of the complainant;
It constitutes due process.

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Grounds for Disbarment or Suspension:


deceit;
malpractice or other gross misconduct in office;
grossly immoral conduct;
conviction of a crime involving moral turpitude;
violation of oath of office;
willful disobedience of any lawful order of a superior court;
corrupt or willful appearance as attorney for a party to case without authority to do so (Sec. 27, Rule 138,
RRC)

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Procedure for Disbarment


Institution either by:
the Supreme Court, motu proprio, or
the IBP, motu proprio, or
upon verified complaint by any person
Six copies of the verified complaint shall be filed with the Secretary of the IBP or Secretary of any of its
chapter and shall be forwarded to the IBP Board of Governors.
6. Investigation by the National Grievance Investigators.
7. Submission of investigative report to the IBP Board of Governors.
8. Board of Governors decides within 30 days.
9. Investigation by the Solicitor-General
10. SC renders final decision for disbarment/suspension/dismissal.
Quantum of Proof Required: CLEAR, CONVINCING & SATISFACTORY evidence.
Burden of Proof:Rests on the COMPLAINANT, the one who instituted the suit

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Officers authorized to investigate Disbarment cases:


Supreme Court
IBP through its Commission on Bar Discipline or authorized investigator
Office of the Solicitor General

Mitigating Circumstances in Disbarment:

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Good faith in the acquisition of a property of the client subject of litigation (In re: Ruste, 70 Phil. 243)
Inexperience of the lawyer (Munoz v. People, 53 SCRA 190)
Age (Lantos v. Gan, 196 SCRA 16)
Apology (Munoz v. People, 53 SCRA 190)

Lack of Intention to slight or offend the Court (Rhum of the Philippines, Inc. v. Ferrer, 20 SCRA 441).
Grounds for Disbarment or Suspension of a Lawyer
1. Deceit
Cham vs. Atty. Edilberto D. Pizarro
A.C. No. 5499, August 16, 2005
A lawyer was subjected to disciplinary action for selling a non-disposable land of the public domain. He violated his
oath not to do falsehood and misrepresentation to the buyer-complainant.
Co vs. Bernardino, 285 SCRA 102 [1998]
Lao vs. Medel, 405 SCRA 227 [2003]
For a lawyer to be dealt with by the Supreme Court, the transaction entered into need not be in the performance
of professional services. It can be in his private capacity.
Professional honesty and honor are not to be expected as the accompaniment of dishonesty and dishonor in other
relations.
Case references:
Santos vs. Atty. Maria Vivane
Cacho-Calicdan, September 19, 2006
2. Malpractice
Nakpil vs. Atty. Carlos J. Valdes
March 4, 1998
A lawyer violated the trust and confidence of the client when he represented conflicting interest. He represented
the creditors when his accounting firm prepared and computed the claims of the creditors while his law firm
represented the estate.
Case references:
Buted vs. Hernando, 203 SCRA 1
Maturan vs. Gonzales, March 12, 1998
Conflict of interest
(Pormento vs. Pontevedra, March 31, 2005)
A lawyer has to disclose to his client all the circumstances of his relations to the parties in connection with the
controversy which might influence the client in the selection of counsel.
It is unprofessional to represent conflicting interests except by express consent of all concerned given after full
disclosure of the facts.

Tests to determine if there is conflicting interests:


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If the acceptance of the new retainer will require the attorney to do anything which will injuriously affect
his first client in any matter in which he represents him and also whether he will be called upon in his new relation,
to use against his first client any knowledge acquired thru their connection;
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Whether the acceptance of a new relation will prevent an attorney from full discharge of his duty of
undivided fidelity and loyalty to his client or invite suspicion of unfaithfulness or double dealing in the performance
thereof.
Reason for prohibition
The reason for the prohibition is found in the relation of attorney and client, which is one of trust and confidence
of the highest degree. A lawyer becomes familiar with all the facts connected with his clients case. He learns from
his client the weak points of the action as well as the strong ones. Such knowledge must be considered sacred and
guarded with care. No opportunity must be given him to take advantage of his clients secrets. A lawyer must have
the fullest confidence of his client. For, if the confidence is abused, the profession will suffer by the loss thereof.
The prohibition applies however slight such adverse interest may be (Nakpil vs. Valdes, 286 SCRA 758).
The essence of the rule is to maintain inviolate the clients confidence or to refrain from obtaining anything which
will injuriously affect in any matter in which he previously represented him.
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Grossly immoral conduct
Emma Dantes vs. Atty. Crispin Dantes
A.C. No. 6488, September 22, 2004
The wife complained that her husband was a philanderer, having illicit relationship with two women. He was
disbarred. A lawyer must demonstrate that he or she has good moral character and should behave in accordance
with the standards.
Case references:
Barrientos vs. Daarol, 218 SCRA 30
Toledo vs. Toledo, 7 SCRA 757
Obusan vs. Obusan, 128 SCRA 485
Terre vs. Terre, July 3, 1992
Santos vs. Tan, 196 SCRA 16
St. Louis Univ. Laboratory High School Faculty & Staff vs. Atty. Dela Cruz, A.C. No. 6010, August 28, 2006
Disbarment should never be decreed where any lesser penalty could accomplish the end desired; hence, the
penalty of two years suspension was more appropriate.
A lawyer got married again after his failed marriage. He never absconded his obligations to his first wife and child.
After the annulment of his second marriage, he remained celibate. He was humble enough to offer no defense
save for his lone and declaration of his commitment to his wife and child. (Conjuangco vs. Palma, 438 SCRA 306;
462 SCRA 310 [2005]).

Zaguirre vs. Castillo


398 SCRA 658 [2003]
465 SCRA [2005]
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Conviction of a crime involving moral turpitude


In the Matter of Disbarment Proceedings vs. Narciso Jaranillo, 101 Phil. 323

A lawyer was disbarred for having been convicted of estafa.


b.

In Re: Dalmacio delos Angeles, 106 Phil. 1

A lawyer was convicted of the crime of bribery. He was disbarred.


Case references:
In Re: Disbarment of Rodolfo Pajo, 203 Phil. 79
In Re: Atty. Isidro Vinzons, 126 Phil. 96
Barrios vs. Atty. Francisco Martinez, A.C. No. 4885, November 12, 2004
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Violation of the Lawyers Oath


Judge Ubaldino Larucon vs. Atty. Ellis Jacoba, A.C. No. 5921, March 10, 2006

In his motion, the lawyer stated:


The judgment is an abhorrent nullity, legal monstrosity, horrendous mistake, horrible error, an insult to
the judiciary, and an anachronism in the judicial process.
The lawyer was suspended. The language exceeded the vigor required of a lawyer to defend ably his clients cause.
b.

Almendrez vs. Atty. Minervo Langit, A.C. No. 7057, July 25, 2006

A lawyer was suspended for having appropriated the rental deposits for his client in an ejectment suit.
c.

Suspension from the Practice of Law in the Territory of Guam of Atty. Leon G. Maquera, 435 SCRA 417

A lawyer who was suspended from the practice of law abroad may likewise be sanctioned in the Philippines for
infraction he committed abroad. (Velez vs. De Vera, A.C. No. 6697, July 25, 2006).
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Willful disobedience to any lawful order of a superior court


People vs. Dalusog, 62 SCRA 540;

Luzon Mahogany Timber Ind., Inc. vs. Castro, 69 SCRA 384;


People vs, Medina, 62 SCRA 253;
Geeslin vs. Navarro, 185 SCRA 230
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Willfully appearing as attorney for any party without authority
(Sec. 27, Rule 138, Rules of Court; Atty. Edilberto D. Pizarro, A.C. No. 5499, August 16, 2005)

a.

Porac Trucking Corp. vs. CA, 202 SCRA 674; Garrido vs. Quisumbing, 28 SCRA 614

A lawyer was suspended from the practice of law in appearing for a party defendant without authority.
A judge may require a lawyer to prove that he is authorized to appear for a client.
b.

Mercado vs. Ulay, 187 SCRA 720

Reinstatement After Suspension or Disbarment


a. In Re: Petition to Take the Lawyers Oath of Arthur Cuevas, Jr., January 27, 1988
A new lawyer was allowed to take his oath after his discharge from probation without any infraction of the
conditions. He was given the benefit of the doubt.

b. Fernandez vs. Grecia, June 17, 1993

The act of stealing the exhibits can be treated as an unlawful and dishonest act of a lawyer, a violation of his
bounden duty to uphold the Code of Professional responsibility.
Zaldivar vs. Gonzales, 166 SCRA 316
A lawyer who was suspended was reinstated after cleansing himself. He used intemperate and unfair criticism
against the Supreme Court in gross violation of the duty of respect to the courts.
Petition for Leave to Resume Practice of Law, Benjamin Dacanay, B.M. No. 1678, December 17, 2007. He was
allowed subject to compliance with requirements of the Rules, especially so that he became a Canadian citizen
later. He has to reacquire his Filipino citizenship and apply for a permit to practice law.
The practice of law is a sacred and noble profession. It is limited to the persons of good moral character with
special qualifications duly ascertained and certified.

The Lawyer's Oath


By J. Jose L. Sabio, Jr.
The Oath: The Lawyer's Ideal
What is an oath? Webster defines it as: A solemn appeal to God, or in a wider sense, to any sacred or
revered person or sanction for the truth of an affirmation or declaration or in witness of the inviolability of a
promise or undertaking. As early as Alvarez vs. CFI, the Supreme Court explained its meaning in this wise:
In its broadest sense, an oath includes any form of attestation by which a party signifies that he is bound in
conscience to perform an act faithfully and truthfully. It is an outward pledge given by the person taking it,
that his attestation or promise is made under an immediate sense of his responsibility to God.
Section 17 of Rule 138 of the Rules of Court states that an applicant who has passed the required
examination, or has been otherwise found to be entitled to admission to the bar, shall take and subscribed
before the Supreme Court an oath of office. The new lawyer swears before a duly constituted authority as an
attestation that he/she takes on the duties and responsibilities proper of a lawyer. More particularly, form 28
of the judicial standard forms prescribes the following oath to be taken by the applicant:
I___________ of ___________ do solemnly swear that I will maintain allegiance to the Republic of the
Philippines; I will support its Constitution and obey laws as well as the legal orders of the duly constituted
authorities therein; I will do no falsehood, nor consent to the doing of any court; I will not wittingly nor
willingly promote or sue any groundless, false or unlawful suit, or give aid nor consent to the same; I will
delay no man for money or malice, and will conduct myself as a lawyer according to the best of my
knowledge and discretion with all good fidelity as well to the courts as to my clients; and I impose upon
myself this voluntary obligations without any mental reservation or purpose of evasion. So help me God.
The taking of this oath is a condition to the admission to practice law and may only be taken before the
Supreme Court by a person authorized by the high court to engage in the practice of law. And what is the
nature of a lawyer's oath? In the case of Sebastian vs. Calis the Supreme Court held that: A lawyer's oath
are not mere facile words, drift and hollow, but a sacred trust that must be upheld and kept inviolable. The
substance and gravity behind these words may be understood in the light of the substance and gravity
behind the oath being taken. In a sense, the oath embodies the ideals by which a lawyer lives by in the
practice of the legal profession. This is why the lawyer's oath has been likened to a condensed version of the
canons of professional responsibility. This seems to have been confirmed in Endaya vs. Oca, where it was
held that: the lawyer's oath embodies the fundamental principles that guide every member of the legal
fraternity. From it springs the lawyer's duties and responsibilities that any infringement thereof can cause
his disbarment, suspension or other disciplinary actions.
In the words of the Supreme Court, an oath is any form of attestation by which a party signifies that he is
bound in conscience to perform an act faithfully and truthfully. What then does a lawyer promise to perform
faithfully and truthfully when he takes on the oath upon being admitted to the practice of law? It is the very
practice of his duties and responsibilities as a lawyer. The gravity of the oath is grounded on two important
things: on the gravity of a lawyer's duties and on the fact that he makes a solemn promise before God to
undertake these duties faithfully. When a great amount of trust is placed on such an office, then a
corresponding sense of integrity and responsibility is expected of those who have taken on that office. The
legal profession is one such office laden with a great amount of trust. In the hands of the lawyer is entrusted
not only the power to steer the course of some client's personal or business future but more importantly,
the very nature of the legal profession presupposes a certain moral burden that demands personal integrity.
As stated by the Supreme Court:
Lawyers are expected to abide by the tenets of morality, not only upon admission to the Bar but also
throughout their legal career, in order to maintain one's good standing in that exclusive and honored
fraternity. Good moral character is more than just the absence of bad character. Such character expresses
itself in the will to do the unpleasant thing if it is right and the resolve not to do the pleasant thing if it is

wrong. This must be so because vast interests are committed to his care; he is the recipient of unbounded
trust and confidence; he deals with his client' s property, reputation, his life, his all.
A lawyer is said to be the servant of the law and belongs to a profession to which society has entrusted the
administration of law and the dispensing of justice. For this reason, a lawyer's oath impresses upon him the
responsibilities of an officer of the court upon whose shoulders rest the grave responsibility of assisting
courts in the proper, fair, speedy and efficient administration of justice.
In fact, it may be understood that the words contained in the oath of office summarize the main duties and
responsibilities a lawyer is supposed to take on in the practice of law. In other words, every time an oath of
office is taken, the person making the statement in effect states that in taking on the oath he/she promises
to conscientiously fulfill the duties entrusted to his office. Section 20 of Rule 138 enumerates what these
duties are. It is the duty of an attorney (a) To maintain allegiance to the Republic of the Philippines and to support the Constitution and obey the
laws of the Philippines;
(b) To observe and maintain the respect due to the courts of justice and judicial officers;
(c) To counsel or maintain such actions or proceedings only as appearing to him to be just, and such
defenses only as he believes to be honestly debatable under the law;
(d) To employ, for the purpose of maintaining the causes confided to him, such means only as are
consistent with truth and honor, and never seek to mislead the judge or any judicial officer by an artifice or
false statement of fact or law;
(e) To maintain inviolate the confidence, and at every peril to himself, to preserve the secrets of his client,
and to accept no compensation in connection with his clients' business except from him or with his
knowledge and approval;
(f) To abstain from all offensive personality and to advance no fact prejudicial to the honor or reputation of a
party or witness, unless required by the justice of the cause with which he is charged;
(g) Not to encourage either the commencement or the continuance of an action or proceeding, or delay any
man's cause, from any corrupt motive or interest;
(h) Never to reject, for any consideration personal to himself, the cause of the defenseless or oppressed;
(i) In the defense of a person accused of crime, by all fair and honorable means, regardless of his personal
opinion as to the guilt of the accused, to present every defense that the law permits, to the end that no
person may be deprived of life or liberty, but by due process of law.
In order to fulfill these duties, every lawyer is expected to live by a certain mode of behavior now distilled in
what is known as the Code of Professional Responsibility. The Code mandates upon each lawyer, as his duty
to society, the obligation to obey the laws of the land and promote respect for law and legal processes.
Specifically, he is forbidden to engage in unlawful, dishonest, immoral or deceitful conduct. In essence, all
that is contained in this Code is succinctly summarized in the oath of office taken by every lawyer. It is of
little surprise to find that inMagdaluyo vs. Nace the Supreme Court declares that the lawyer's oath is a
source of obligations and violation thereof is a ground for suspension, disbarment or other disciplinary
action. In the case of Businos vs. Ricafort, the Supreme Court also held that:
By swearing the lawyer's oath, an attorney becomes a guardian of truth and the rule of law, and an
indispensable instrument in the fair and impartial administration of justice a vital function of democracy, a
failure of which is disastrous to society. While the duty to uphold the constitution and obey the laws is an
obligation imposed upon every citizen, a lawyer assumes responsibilities over and beyond the basic
requirements of good citizenship. As servant of the law, a lawyer ought to make himself an example for
others to emulate. He should be possessed of and must continue to possess good moral character.

In Brion Jr. vs. Brillantes, Jr., the Supreme Court also ruled: the lawyer's primary duty as enunciated in the
attorney's oath is to uphold the constitution, obey the laws of the land and promote respect for the law and
legal processes. That duty in its irreducible minimum entails obedience to the legal orders of the court. The
importance and significance in upholding the sanctity of a lawyer's oath have been highlighted by the
Supreme Court in the various rulings it made involving disciplinary actions against members of the legal
fraternity.
The Real World Of The Legal Practice
While it is true that these ideals by which every lawyer swears to live by remain sublime, the same ideals
often hardly motivate some lawyers in the real world of legal practice. Instead of high ideals, less honorable
reasons and more pragmatic considerations often financial and material in nature take hold of many a
cynical and hardened lawyer. This has been the cause of lament and expressions of grave concern by
honorable individuals, among them the late Supreme Court Chief Justice Fred Ruiz Castro. In an address
before members of the legal profession, he said:
Many a legal practitioner, forgetting his sacred mission as a sworn public servant and his exalted position as
an officer of the court, has allowed himself to become:
An instigator of controversy, instead of a mediator for concord and a conciliator for compromise;
A virtuoso of technicality in the conduct of litigation, instead of a true exponent of the primacy of truth and
moral justice;
A mercenary purveying the benefits of his enlightened advocacy in direct proportion to a litigant's financial
posture, instead of a faithful friend of the courts in the dispensation of equal justice to rich and poor alike.
Though these words were expressed some time ago, yet is is sad to note that Chief Justice Ruiz's words still
ring loud and true today. The goal of remaining true to the ideals of the legal profession is hampered by the
seemingly irresistible influence and pressures of modern day commercialism in almost every facet of human
activity and endeavor. In various cases, the Supreme Court has denied applicant's petition to take the
lawyer's oath for grave misconduct or for any serious violation of the canons of professional responsibility
which puts in question the applicant's moral character. Moreover, a reading of the latest rulings of the
highest tribunal would reveal the lawyer's utter disregard, if not disdain, for the lawyer's oath.
In Vitriola vs. Dasig, a case for disbarment against an official of the commission on higher education charged
with gross misconduct in violation of the attorney's oath for having used her public office to secure financial
spoils, the Supreme Court, in ordering respondent's disbarment, held:
The attorney's oath is the source of the obligations and duties of every lawyer and any violation thereof is a
ground for disbarment, suspension, or other disciplinary action. The attorney's oath imposes upon every
member of the bar the duty to delay no man for money or malice.
Said duty is further stressed in Rule 1.03 of the code of professional responsibility. Respondent's demands
for sums of money to facilitate the processing of pending applications or requests before her office violates
such duty, and runs afoul of the oath she took when admitted to the bar.
The affirmation by a lawyer to uphold the law was the subject in De Guzman vs. De Dios. In this case where
respondent was charged for representing conflicting interest, found guilty and suspended for six months,
with a warning, the highest tribunal held:
To say that lawyers must at all times uphold and respect the law is to state the obvious, but such statement
can never be over-emphasized. Considering that, 'of all classes and professions, (lawyers are) most sacredly
bound to uphold and respect the law', it is imperative that they live by the law.
Accordingly, lawyers who violate their oath and engage in deceitful conduct have no place in the legal
profession. As a lawyer, respondent is bound by her oath to do no falsehood or consent to its commission
and to conduct herself as a lawyer to the best of her knowledge and discretion. The lawyer's oath is a source

of obligation and violation thereof is a ground for suspension, disbarment, or other disciplinary action. The
acts of respondent Atty. De Dios are clearly in violation of her solemn oath as a lawyer that this court will
not tolerate.
In Sevillano Batac, Jr., et al. vs. Atty. P. Cruz, Jr., the Supreme Court in ordering the suspension of
respondent, quoted Sec. 27 of Rule 138 of the Revised Rules of Court, thus:
Section 27. Disbarment or suspension of attorneys by supreme court; grounds therefor: A member of the
bar may be disbarred orsuspended from his office as attorney by the Supreme Court for any deceit,
malpractice, or, other gross misconduct in such office, grossly immoral conduct, or by reason of his
conviction of a crime involving moral turpitude, or for any violation of the oath which he is required to take
before admission to practice, or for a willful disobedience of any lawful order of a superior court, or for
corruptly or willfully appearing as an attorney for a party to a case without authority so to do.
The practice of soliciting cases at law for the purpose of gain, either personally or through paid agents or
brokers, constitutes malpractice. A lawyer, under his oath, pledges himself not to delay any man for money
or malice and is bound to conduct himself with all good fidelity to his client. Such was the pronouncement of
the Supreme Court in ordering the disbarment of lawyer who converted the money of his client to his own
personal use without her consent. The lawyer's oath exhorts law practitioners not to wittingly or willingly
promote or sue any groundless, false or unlawful suit, nor give aid nor consent to the same. In Young vs.
Batuegas, where respondent was suspended for six months for knowingly alleging an untrue statement of
fact in his pleading, the Supreme Court said, thus:
A lawyer must be a disciple of truth. He swore upon his admission to the bar that he will 'do no falsehood
nor consent to the doing of any in court' and he shall conduct himself as a lawyer according to the best of
his knowledge and discretion with all good fidelity as well to the courts as to his clients. He should bear in
mind that as an officer of the court his high vocation is to correctly inform the court upon the law and the
facts of the case and to aid it in doing justice and arriving at a correct conclusion.
The courts, on the other hand, are entitled to expect only complete honesty from lawyers appearing and
pleading before them. While a lawyer has the solemn duty to defend his client's rights and is expected to
display the utmost zeal in defense of his client's cause, his conduct must never be at the expense of truth.
That a lawyer's oath are not mere facile words, drift and hollow, was applied by the Supreme Court in Vda.
De Rosales vs. Ramos, where a notary public commission was revoked and respondent disqualified from
being a notary public, in this manner: where the notary public is a lawyer, a graver responsibility is placed
upon him by reason of his solemn oath to obey the laws and to do no falsehood or consent to the doing of
any.
Indeed when an office entrusted with great responsibility and trust by society is violated and abused, one
finds truth in the expression corruptio optimi pessima (the corruption of the best is the worst). The words of
former Presiding Justice of the Court of Appeals Pompeyo Dias cannot find a more relevant application:
There are men in any society who are so self-serving that they try to make law serve their selfish ends. In
this group of men, the most dangerous is the man of the law who has no conscience. He has, in the arsenal
of his knowledge, the very tools by which he can poison and disrupt society and bring it to an ignoble end.
A Return to Basic Ideals
With the glaring reality of legal practice evidenced by the increasing numbers of administrative cases filed
against lawyers in the Courts, it is no surprise therefore that legal ethics has been prescribed as a subject
under the Mandatory Continuing Legal Education (MCLE). Moreover, of the 36 units prescribed under the
MCLE, six units pertain to legal ethics. There is clearly a perceived need to instill legal ethics in the practice
of the legal profession. The pressing need for legal ethics was highlighted by the Supreme Court in Endaya
vs. Oca:
For practical purposes, the lawyers not only represent the law; they are the law. With their ubiquitous
presence in the social milieu, lawyers have to be responsible. The problems they create in lawyering become

public difficulties. To keep lawyers responsible underlies the worth of the ethics of lawyering. Indeed, legal
ethics is simply the aesthetic term for professional responsibility.
Undoubtedly, faithful compliance and observance of the canons of the Code of Professional Responsibility is
the main object of the MCLE. And to ensure success thereof, the Supreme Court, in its various
pronouncements in administrative cases filed against lawyers, has emphasized the lawyer's basic duties and
responsibilities. In a more recent ruling, the Supreme Court recapitulated the significance and importance of
the oath in this wise: This oath to which all lawyers have subscribed in solemn agreement to dedicate
themselves to the pursuit of justice is not a mere ceremony or formality for practicing law to be forgotten
afterwards; nor is it mere words, drift and hollow, but a sacred trust that lawyers must uphold and keep
inviolable at all times. By swearing the lawyer's oath, they become guardians of truth and the rule of law, as
well as instruments in the fair and impartial dispensation of justice.
Indeed, if the legal profession is to achieve its basic ideal to render public service and serve the ends of
justice, there is a need to unceasingly and constantly inculcate professional standards among lawyers. As
the Supreme Court in Cordon vs. Balicanta (supra), said: If the practice of law is to remain an honorable
profession and attain its basic ideal, those enrolled in its ranks should not only master its tenets and
principles, but should also in their lives accord continuing fidelity to them.

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