Manila
SECOND DIVISION
[ A.C. No. 13435 (Formerly CBD Case No. 18-5815), February 05, 2025 ]
DENIS GUY MARTIN, COMPLAINANT, VS. ATTY. LETICIA E. ALA, RESPONDENT.
D E C I S I O N
KHO, JR., J.:
Before the Court is a Complaint1 for disbarment filed on August 9, 2018 by complainant Denis Guy Martin (complainant) before the Integrated Bar of the Philippines (IBP) Commission on Bar Discipline, accusing respondent Atty. Leticia E. Ala (respondent) of violating the Lawyer's Oath and the Code of Professional Responsibility (CPR).
The Facts
Complainant, a French national, was married to respondent's sister, Rebecca E. Ala-Martin (Rebecca). In 1992, complainant and Rebecca separated legally. Thereafter, the couple filed cases against each other, with respondent representing her sister Rebecca.2
Sometime in 2006, complainant filed a Complaint for disbarment against respondent for allegedly representing conflicting interests and for using abusive and offensive language, titled Martin v. Atty. Ala and docketed as CBD Case No. 06-1846. The IBP Investigating Commissioner, as adopted and approved by the IBP Board of Governors, eventually found respondent administratively liable and, accordingly, recommended her suspension from the practice of law for two months. Respondent's subsequent Motion for Reconsideration was denied by the IBP Board of Governors in a Resolution dated September 20, 2008.3
Thereafter, sometime in January 2017, respondent filed a Complaint for deportation (as Undesirable Alien) against complainant before the Bureau of Immigration (BI). Subsequently, on April 17, 2017, an apparent altercation occurred between respondent and complainant's son/respondent's nephew, Jean Marc. Because of these incidents, complainant filed the instant Complaint for disbarment against respondent.4
Particularly, complainant charged respondent with attempted murder and with violating the Lawyer's Oath, as well as Rules 1.01 and 1.02 of Canon 1 of the CPR for allegedly ordering the responding police officers during the incident on April 17, 2017 to shoot or kill Jean Marc, respondent's nephew. Complainant likewise charged respondent with violating Canon 15, Rule 15.03 of the CPR for representing conflicting interests in connection with the deportation case she filed against the former. In this respect, complainant claimed that respondent used information previously obtained when she, through her law firm, was a counsel for the Drilling & Blasting Management Group, Inc., of which Rebecca was the President, albeit, complainant did not clarify his exact relation to the said company.5 Finally, complainant asserted that respondent continues to use abusive and offensive language in her pleadings despite the previous sanction and warning given by the Court in A.C. No. 10556, in violation of Canon 8, Rule 8.01 of the CPR.6
In defense, respondent denied all the allegations against her and claimed that the previous case against her, A.C. No. 10556, is still pending before the Court.7
The IBP Proceedings
In a Report and Recommendation8 dated September 13, 2019, the IBP Investigating Commissioner (IC) found respondent guilty of employing offensive and improper language in her pleadings and, accordingly, recommended that respondent be admonished, with a stem warning that a repetition of the same or similar offense shall be dealt with more severely.9
The IBP-IC found respondent administratively liable for violating Canon 1, Rule 1.0 of the CPR and the Lawyer's Oath for repeatedly urging the police officers to shoot her nephew, Jean Marc, during the April 17, 2017 incident. The IBP-IC, however, noted that when respondent ordered the same, she was under distress due to Jean Marc's actions and thus, betrayed the lack of any. apparent intention on her part to commit a wrong.10
In the same vein, the IBP-IC found respondent liable for violating Canon 8, Rule 8.01 of the CPR for using abusive and offensive words in her various submissions before the BI in the deportation case.11
The foregoing notwithstanding, the IBP-IC found no merit in complainant's claim that respondent is guilty of representing conflicting interests in connection with the deportation case. The IBP-IC held that conflict of interest does not exist when it is the lawyer themself that files the case against their former client, as in this case. Moreover, the IBP-IC noted that the record failed to indicate that there was any confidential information which respondent may have acquired from her previous representation of complainant which she used in filing the deportation case.12
Parenthetically, however, the IBP-IC did not consider the findings in CBD Case No. 06-1846, noting that the same is still pending before the Court.13
In a Resolution14 dated June 12, 2021, the IBP Board of Governors (IBP Board) resolved to approve and adopt the Report and Recommendation of the IC.
Dissatisfied, complainant moved for reconsideration, arguing that the findings in CBD Case No. 06-1846 should be considered in the resolution of the present case and respondent should be disbarred in view of the gravity of her administrative infractions.15
In a Resolution16 dated February 25, 2022, the IBP Board upheld with modification the June 12, 2021 Resolution, finding respondent guilty of violating Canons 1 and 8 of the CPR, and accordingly, recommended the penalty of reprimand with a stern warning that a repetition of the same or similar offense shall be dealt with more severely.
In the interim, the Court adopted the IBP's Report and Recommendation, with modification, in A.C. No. 10556 (formerly CBD Case No. 06-1846), in a Resolution dated June 30, 2021. Consequently, respondent was admonished and sternly warned that a repetition of the same or similar acts shall be dealt with more severely.
The Issue Before the Court
The issue before the Court is whether respondent should be held administratively liable for the acts complained of.
The Court's Ruling
The Court resolves to adopt the findings and recommendation of the IBP, with modification as will be further discussed hereunder.
I
At the outset, it is important to note that on April 11, 2023, the Court En Banc unanimously approved A.M. No. 22-09-01-SC or the "Code of Professional Responsibility and Accountability" (CPRA), repealing the CPR, Sections 20 to 37 of Rule 138, and Rule 139-B of the Rules of Court. Section 3 of the General Provisions of the CPRA states that it "shall take effect fifteen (15) calendar days after its publication in the Official Gazette or any newspaper of general circulation." The CPRA was published in the Philippine Star and Manila Bulletin on May 14, 2023 and hence, already effective on May 30, 2023.17
In this relation, Section 1 of the General Provisions of the CPRA states that it "shall be applied to all pending and future cases, except to the extent that in the opinion of the [Court], its retroactive application would not be feasible or would work injustice, in which case the procedure under which the cases were filed shall govern."
In view of the foregoing, the Court shall resolve this case under the framework of the CPRA, to the extent that it is applicable.
II
Time and again, the Court has emphasized that the practice of law is imbued with public interest and that a lawyer owes substantial duties, not only to their client, but also to their brethren in the profession, to the courts, and to the public, and takes part in the administration of justice, one of the most important functions of the State, as an officer of the court. Accordingly, lawyers are bound to maintain, not only a high standard of legal proficiency, but also of morality, honesty, integrity, and fair dealing.18
Indeed, it is settled that the practice of law is not a right, but a privilege bestowed by the State on those who show that they possess, and continue to possess, the qualifications required by law for the conferment of such privilege. To this end, a member of the legal fraternity should refrain from doing any act which might lessen in any degree the confidence and trust reposed by the public in the fidelity, honesty, and integrity of the legal profession.19 Accordingly, lawyers may be disciplined for any conduct, whether in their professional or in their private capacity, if such conduct renders them unfit to continue to be officers of the court.20
In this regard, Canon II of the CPRA requires lawyers to always act with propriety and maintain the appearance of propriety in personal and professional dealings, observe honesty, respect and courtesy, and uphold the dignity of the legal profession consistent with the highest standards of ethical behavior. It pertinently reads:
CANON II
PROPRIETY
A lawyer shall at all times, act with propriety and maintain the appearance of propriety in personal and professional dealings, observe honesty, respect and courtesy, and uphold the dignity of the legal profession consistent with the highest standards of ethical behavior.
SECTION 2. Dignified conduct. – A lawyer shall respect the law, the courts, tribunals, and other government agencies, their officials, employees, and processes, and act with courtesy, civility, fairness, and candor towards fellow members of the bar.
A lawyer shall not engage in conduct that adversely reflects on one's fitness to practice law, nor behave in a scandalous manner, whether in public or private life, to the discredit of the legal profession.
SECTION 4. Use of dignified, gender-fair, and child- and culturally-sensitive language. – A lawyer shall use only dignified, gender-fair, and child- and culturally-sensitive language in all personal and professional dealings.
To this end, a lawyer shall not use language which is abusive, intemperate, offensive or otherwise improper, oral or written, and whether made through traditional or electronic means, including all forms or types of mass or social media.
SECTION 6. Harassing or threatening conduct. – A lawyer shall not harass or threaten a fellow lawyer, the latter's client or principal, a witness, or any official or employee of a court, tribunal, or other government agency.
SECTION 13. Imputation of a misconduct, impropriety, or crime without basis. – A lawyer shall not, directly or indirectly, impute to or accuse another lawyer of misconduct, impropriety, or a crime in the absence of factual or legal basis. (Emphasis supplied)
In addition, Canon III mandates lawyers to uphold the Constitution and the laws of the land, promote respect for laws and legal processes, assist in the administration of justice as an officer of the court, safeguard human rights, and always advance the honor and integrity of the legal profession. It relevantly states:
CANON III
FIDELITY
Fidelity pertains to a lawyer's duty to uphold the Constitution and the laws of the land, to assist in the administration of justice as an officer of the court, and to advance or defend the client's cause, with full devotion, genuine interest, and zeal in the pursuit of truth and justice.
. . . .
SECTION 2. The responsible and accountable lawyer. – A lawyer shall uphold the constitution, obey the laws of the land, promote respect for laws and legal processes, safeguard human rights, and at all times advance the honor and integrity of the legal profession.
Lastly, Canon III of the same Code proscribes lawyers from representing conflicting interests, except by written informed consent of all concerned given after a full disclosure of the facts.21
Applying the foregoing precepts, the Court agrees with the IBP that respondent should be held administratively liable.
III
Unlawful conduct
The Court agrees with the IBP that respondent should be held administratively liable in connection with her conduct during the April 17, 2017 incident. As the IBP astutely observed, respondent urged the responding police officers to shoot her nephew, Jean Marc, several times despite the police officers' refusal to heed her instructions in view of existing legal and police procedures. To quote pertinent portions of the exchanges between respondent and the police officers, as narrated in the April 18, 2017 Affidavit of Arrest of PO3 Trivar Valena y Dela Cruz:
". . . Ang sabi ni [respondent] sa amin ay: 'For God's sake! Patayin niyo na si Jean Marc! Barilin nyo na kesa tayo pa ang maunahan niya dito! Simple target hindi niyo pa magawang barilin?!' . . . Ma'am hindi po ganun kadali ang pinapagawa niyo! Unang una eh wala pa naman po ginagawang hakbang si Jean Marc para gawin namin ang gusto niyo! Tsaka kailangan pa po naming isangguni iyon sa aming Hepe! Pag nagka imbestigasyonpo eh kami pa and makakasuhan ng Murder sa gusto niyong mangyari!' agad naman itong sumagot sa amin na: 'Bakit inaalala niyo ang Complainant? Wala naman complainant! Kami?! Hindi naman kami magcocomplain kaya barilin niyo na at naghahanap nalang iyan ng damay! . . . "Ano ba? Bakit hindi niyo pa barilin! Patayin niyo na! Ano ba!'. . . 'Anu Ba? Barilin niyo na! kahit sa paa niyo lang patamaan para hindi na siya makatakas pa! dahil dadalhin naming siya agad agad sa Metro Psych doon namin siya ilalagay para hindi na siya makalabas doon . . ."22
As an officer of the court, it behooved respondent to ensure that the Constitution and the laws, including legal processes, are observed not only in her conduct and dealings with others, but also by those around her. Indeed, the CPRA requires lawyers to "uphold the constitution, obey the laws of the land, promote respect for laws and legal processes, safeguard human rights, and at all times advance the honor and integrity of the legal profession."23 It also proscribes lawyers from engaging in conduct that adversely reflects on their fitness to practice law, and behaving in a scandalous manner, whether in public or private life, to the discredit of the legal profession.24
Verily, respondent's actuations in this case demonstrate a conscious disrespect of the laws and legal processes in repeatedly pressing the responding police officers to shoot Jean Marc despite the apparent absence of any cause to warrant such police action. Worse, her actions betrayed a marked disregard for her nephew's basic right not to be deprived of life and liberty without due process of the law.
On this score, the Court notes the IBP's observation that there appeared to have been no manifest and deliberate intention on the part of respondent to commit a wrong when she repeatedly instructed the police officers to shoot Jean Marc.25 Indeed, under the circumstances, it can hardly be doubted that respondent may have been impelled by strong emotions of fear and/or distress and the need to protect her family, especially since it appeared that it was not the first instance that Jean Marc's actions caused police officers to respond. Certainly, the Court will not feign comprehension of all the complex and varied reactions any person may have in such situations.
Nonetheless, as an officer of the court, respondent is charged with the duty to refrain from doing any act which might lessen in any degree the confidence and trust reposed by the public in the fidelity, honesty, and integrity of the legal profession. Lawyers must at all times uphold and respect the laws and its processes. As such, it behooved respondent to observe a greater degree of prudence and circumspection in her actions and words at all times, gravely failing in which will warrant administrative sanction.
Use of intemperate or abusive language
In the same vein, the Court agrees that respondent should be held liable for using intemperate and abusive language.
It cannot be denied that the adversarial nature of our legal system has tempted members of the Bar to use strong language in pursuit of their duty to advance the interests of their clients.26 Nonetheless, while a lawyer is entitled to present their case with vigor and courage, such enthusiasm does not justify the use of offensive and abusive language. Language abounds with countless possibilities for one to be emphatic but respectful, convincing but not derogatory, and illuminating but not offensive.27 The use of intemperate language and unkind ascriptions has no place in the dignity of the judicial forum.28
In this case, as the IBP aptly noted and summarized, respondent essentially accused complainant and his counsel of tampering with records; questioned complainant's dignity; and criticized complainant's counsel's knowledge of basic legal forms and of the laws in her submissions before the BI in the deportation case she filed against complainant, viz.:
Pleadings filed before the BI29
• Verified Comment dated July 11, 2017 (par. 2.1):
"Herein Complainant will NOT take sitting down the FALSE and ABUSIVE ACCUSATIONS of BOTH herein Respondent and counsel; in their little minds, they both EQUATE herein Respondent's 'persona' AS THE SAME as that of Drilling @ Blasting Management Group, Inc."
• Comment dated July 18, 2017 (par. 2):
"For all the braggadocio of herein Respondent Martin AND his counsel, it is noteworthy that said counsel does not even know FORMS of pleadings; moreover, after being told that herein Respondent INTENTIONALLY did NOT have his Counter-Affidavit CERTIFIED CORRECTLY in order NOT to be held for Perjury. They still continue to include a "Certification Against Forum Shopping" in BOTH herein Respondent Martin's Counter-Affidavit AND Memorandum, which under the Rules is ONLY required in INITIATORY pleadings, i.e., a COMPLAINT."
• Motion for Reconsideration dated January 10, 2018 (pp. 8, 10, and 13):
"3.2.a With all due respect, the Resolution that dismissed this present case took an 'extremely parochial" definition of 'undesirability.'
The Undersigned Complainant found it extremely hard to respond politely to the Submissions of herein Respondent in this present case; one only has to read the pleadings of herein Respondent and be able to conclude that he has no 'decent bone' in himself and he had NO qualms making FALSE ALLEGATIONS in them."
"(6.(awÞhi() Corrupting courts, prosecutors and other government entities, including TAMPERING with Court Records.
There have been episodes how herein respondent, through his 'lawyer-operators' would intervene in Court processes, reversal of Resolutions adverse to herein Respondent but which did NOT succeed anyway, 'operating with adverse counsel/s' of REBECCA, the Heinous TAMPERING with resolutions, Court transcripts, etcetera . . . name it, herein Respondent has DONE IT."
"(9.) Bragging about his lawyers-operators that can achieve EVRYTHING for him. Including repeatedly 'operating on adverse counsels'; etcetera."
• Vigorous Reply dated January 30, 2018 (par. 5.2 and p. 8):
"Sometimes, the Undersigned Complainant wonders if herein Respondent's Counsel 'studied and trained' under the same Law Books as the Undersigned Complainant did study and train under at the University of the Philippines College of Law.
What herein Respondent's good counsel does is what is called as 'tonsorial justice,' i.e., merely picking up parts of jurisprudence and the law that suit only its own pathetic views."
"(6.) Corrupting courts, prosecutors and other government entities, including TAMPERING with Court Records.
There have been episodes of how herein Respondent, through his 'lawyer-operators' would intervene in Court processes, reversal of Resolutions adverse to herein Respondent but which did NOT succeed anyway, 'operating with adverse counsel/s' of REBECCA, the Heinous TAMPERING with resolutions, Court transcripts, etcetera . . . name it, herein Respondent has DONE IT." (Emphasis supplied)
To the Court's mind, respondent's statements confirm her arrogance and manifest lack of restraint in the use and choice of her words constituting a clear violation of Canon II, Sections 4 and 13 of the CPRA. On numerous occasions, this Court has reminded members of the Bar to abstain from any offensive personality and to refrain from any act prejudicial to the honor or reputation of a party or a witness. In keeping with the dignity of the legal profession, a lawyer's language even in their pleadings, must be dignified,30 failing in which, they must be held administratively liable, as in this case.
Conflict of interest
Finally, the Court likewise agrees with the IBP that respondent cannot be held liable for conflict of interest when she filed the deportation case against complainant.
Broadly, conflict of interest exists when, in behalf of one client, it is the lawyers' duty to contend for that which duty to another client requires them to oppose.31 It is of no moment that the lawyer would not be called upon to contend for one client that which the lawyer has to oppose for the other client, or that there would be no occasion to use the confidential information acquired from one to the disadvantage of the other as the two actions are wholly unrelated. It is enough that the opposing parties in one case, one of whom would lose the suit, are present clients and the nature or conditions of the lawyer's respective retainers with each of them would affect the performance of the duty of undivided fidelity to both clients.32
In Gimeno v. Atty. Zaide,33 the Court explained the tests to determine whether conflict of interest exists. The Court held:
In Aninon v. Sabitsana, the Court laid down the tests to determine if a lawyer is guilty of representing conflicting interests between and among his clients.
One of these tests is whether the acceptance of a new relation would prevent the full discharge of a lawyer's duty of undivided fidelity and loyalty to the client or invite suspicion of unfaithfulness or double-dealing in the performance of that duty.
Another test is whether a lawyer would be called upon in the new relation to use against a former client any confidential information acquired through their connection or previous employment.34 (Citations omitted; emphasis supplied)
Based on the foregoing characterization, the rule on conflict of interest applies when a lawyer-client relationship exists, the purpose of which is to protect the fiduciary nature of the ties between an attorney and their client. Evidently, the rule finds no application when no such relationship exists, as when it is the lawyer themself that files the case against the former client involving no confidential information obtained from the latter.
In this case, as the IBP aptly observed, respondent was representing herself and there was no indication that she used or abused any confidential information she may previously have acquired from complainant in prosecuting the deportation case. Under these circumstances, the Court holds that the evidence on record fails to support complainant's allegation that respondent is guilty of representing conflicting interests. It bears stressing that the burden of proof in disbarment proceedings rests upon the complainant to satisfactorily prove the allegations in his complaint through substantial evidence.35 As far as the violation of the rule against conflict of interest is concerned, complainant failed in this regard.
IV
A member of the Bar found administratively liable for violating the Lawyer's Oath and/or breaching the ethics of the legal profession may be penalized, or even disbarred or suspended from their office as an attorney. The appropriate penalty on an errant lawyer depends on the exercise of sound judicial discretion based on the surrounding facts.36
Under Canon VI, Section 34(a) and (m) of the CPRA, unlawful conduct and the use of intemperate or offensive language constitute less serious offenses, which under Section 37(b), would warrant the penalties of suspension from the practice of law, fine, or both:
SECTION 37. Sanctions. –
(b) If the respondent is found guilty of a less serious offense, any of the following sanctions, or a combination thereof, shall be imposed:
(1) Suspension from the practice of law for a period within the range of one (1) month to six (6) months, or revocation of notarial commission and disqualification as a notary public for less than two years;
(2) A fine within the range of PHP 35,000.00 to PHP 100,000.00.
Meanwhile, under Canon VI, Section 39 of the CPRA, the presence of one or more aggravating circumstances and absence of any mitigating circumstances may justify the Court in imposing the penalties of suspension or fine for a period or amount not exceeding double the maximum prescribed therein. Relatedly, Section 38(b) of the CPRA enumerates the circumstances which the Court may consider as aggravating, which includes the finding of previous administrative liability where a penalty is imposed, regardless of nature or gravity.
On this score, the Court is cognizant of respondent's previous administrative case, entitled Martin v. Atty. Ala, docketed as A.C. No. 10556, wherein she was found administratively liable for using offensive and improper language in her pleadings and was accordingly admonished. To the Court's mind, this prior finding of administrative infraction on respondent's part shows her propensity to disregard the CPRA and violate the Lawyer's Oath.
Finally, Canon VI, Section 40 of the same Code provides that "[i]f the respondent is found liable for more than one (1) offense arising from separate acts or omissions in a single administrative proceeding, the Court shall impose separate penalties for each offense." Here, as discussed above, respondent violated the following provisions of the CPRA: (a) Canon II, Section 2 and Canon III, particularly Section 2, when she committed unlawful conduct during the April 17, 2017 incident; and (b) Canon II, Sections 4 and 13 when she used intemperate or abusive language in her submissions before the BI.
The foregoing circumstances taken together, the Court deems it proper to impose upon respondent the following penalties: (i) suspension from the practice of law for six months for violating Canon II, Section 2 and Canon III, Section 2 of the CPRA; and (ii) suspension from the practice of law for one year for violating Canon II, Sections 4 and 13 of the CPRA. Further, respondent is sternly warned that a repetition of the same or similar acts shall be dealt with more severely.
ACCORDINGLY, the Court finds respondent Atty. Leticia E. Ala GUILTY of violating the Code of Professional Responsibility and Accountability (CPRA). She is hereby meted with the following penalties, which shall be served successively, pursuant to Section 34(h) and (m), in relation to Sections 38, 39, and 40 of the CPRA:
(1) SUSPENSION from the practice of law for six months for violating Canon II, Section 2 and Canon III, Section 2 of the CPRA; and
(2) SUSPENSION from the practice of law for one year for violating Canon II, Sections 4 and 13 of the CPRA.
Further, she is STERNLY WARNED that a repetition of the same or similar acts shall be dealt with more severely.
The suspension from the practice of law shall take effect immediately upon receipt of this Decision. Atty. Leticia E. Ala is DIRECTED to immediately file a Manifestation to the Court that her suspension has started stating the exact date of receipt of this Decision, copy furnished all courts and quasi-judicial bodies where she has entered her appearance as counsel.
Let a copy of this Decision be furnished the Office of the Bar Confidant to be appended to Atty. Leticia E. Ala's personal record as an attorney, the Integrated Bar of the Philippines for its information and guidance and the Office of the Court Administrator for circulation to all the courts.
After completing her suspension, Atty. Leticia E. Ala shall file with the Office of the Bar Confidant a Sworn Statement pursuant to Section 45 of the Code of Professional Responsibility and Accountability.
SO ORDERED.
Leonen, SAJ. (Chairperson), Lazaro-Javier, M. Lopez, and J. Lopez, JJ., concur.
Footnotes
1 Rollo (Vol. I), pp. 1-24.
2 Id. (Vol. III, Folder IV), p. 3.
3 Id.
4 Id.
5 Id. (Vol. III), p. 4.
6 Id. (Vol. III, Folder IV), pp. 3-4.
7 Id. at 4.
8 Id. at 2-13. Penned by Commissioner Marissa V. Manalo.
9 Id. at 13.
10 Id. at 5-8.
11 Id. at 10-13.
12 Id. at 9-10.
13 Id. at 4.
14 Id. at 1. Signed by National Secretary Roland B. Inting.
15 Id. (Vol. III, Folder IV), pp. 4-28.
16 Id. (Vol. III, Folder IV), pp. 1313-1314. Signed by National Secretary Dorotea Lorenzo B. Aguila.
17 See Request of the Public Attorney's Office to Delete Section 22, Canon III of the Proposed Code of Professional Responsibility and Accountability, A.M. No. 23-05-05-SC [Per J. Gesmundo, En Banc].
18 Yap v. Atty. Buri, 828 Phil. 468, 476-477 (2018) [Per J. Peralta, Second Division].
19 Williams v. Atty. Enriquez, 769 Phil. 666, 673 (2015) [Per J. Mendoza, Second Division].
20 Yap v. Atty. Buri, 828 Phil. 468, 476 (2018) [Per J. Peralta, Second Division].
21 See Canon III, Sections 13 to 22 of the CPRA.
22 Rollo (Vol. III, Folder IV), pp. 6-8.
23 See Canon III, Section 2 of the CPRA.
24 See Canon II, Section 2 of the CPRA.
25 Rollo (Vol. III, Folder IV), p. 8.
26 Saberon v. Atty. Larong, 574 Phil. 510, 516 (2008) [Per J. Carpio Morales, Second Division].
27 Gimeno v. Atty. Zaide, 759 Phil. 10, 23 (2015) [Per J. Brion, Second Division].
28 Noble III v. Atty. Ailes, 762 Phil. 296, 301 (2015) [Per J. Perlas-Bernabe, First Division].
29 Rollo (Vol. III, Folder IV), pp. 11-12.
30 Gimeno v. Atty. Zaide, 159 Phil. 10, 23-24 (2015) [Per J. Brion, Second Division].
31 Parungao v. Atty. Lacuanan, 872 Phil. 747, 756 (2020) [Per J. Hernando, Second Division], citing Quiambao v. Atty. Bamba, 505 Phil. 126, 134-135 (2005) [Per C.J. Davide, Jr., First Division].
32 Id. at 758.
33 759 Phil. 10 (2015) [Per J. Brion, Second Division].
34 Id. at 21.
35 See Canon VI, Section 32 of the CPRA.
36 Jimenez v. Atty. Francisco, 149 Phil. 551, 574 (2014) [Per J. Mendoza, Second Division].
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