Lawyer's Courtroom Conduct and Disciplinary Liability Under the CPRA

The Supreme Court recently reaffirmed that lawyers owe unwavering respect to courts and their personnel, and that misconduct committed while still a member of the Bar can be penalized even after disbarment. In Oncines v. Atty. Causing (A.C. No. 11508, June 10, 2026), the Court imposed fines on a lawyer who shouted at a court employee, demanded retraction of an official certification, and disobeyed directives of the Integrated Bar of the Philippines (IBP).

The case illustrates how the Code of Professional Responsibility and Accountability (CPRA) governs lawyer conduct and how the Court disciplines errant attorneys.

The Facts of the Case

Complainant Bernadette C. Oncines was a Court Legal Researcher II and later officer-in-charge (OIC) of Branch 2, Regional Trial Court, Butuan City. In October 2014, she issued a certification regarding Lot No. 447, which was the subject of a pending land registration case where respondent Atty. Berteni C. Causing served as counsel.

In June 2016, Atty. Causing arrived at the court and angrily shouted at Oncines, demanding she retract the certification she had previously issued. He threatened to file an administrative case against her. Oncines reported the incident to the presiding judge, who advised that she no longer had authority to retract the certification.

Atty. Causing subsequently endorsed an administrative complaint against Oncines. She then filed a disbarment complaint against him, alleging conduct unbecoming of a lawyer.

The Issue Before the Court

The central question was whether Atty. Causing violated the CPRA through his conduct toward the court employee, his imputations against the presiding judge, and his failure to comply with IBP directives.

The Court's Ruling

The Court found Atty. Causing guilty of two violations under the CPRA.

First, he violated Canon II, Section 2, which requires lawyers to respect courts, their officials, employees, and processes, and to act with courtesy, civility, fairness, and candor. The Court noted that as counsel, Atty. Causing should have been the first to uphold the court's authority. Instead, he shouted at Oncines in the presence of her co-employees and a client. He also made baseless accusations of partiality and malice against the presiding judge in his IBP pleadings.

Second, he violated Canon III, Section 2 for willful disobedience of lawful orders. Atty. Causing failed to attend the mandatory conference and file his position paper with the IBP, despite receiving due notice.

However, the Court found insufficient evidence that Atty. Causing promoted a groundless or baseless suit against Oncines. While he endorsed the administrative complaint, the Court held that supporting a client's filing does not clearly prove malicious purpose.

Penalties Despite Prior Disbarment

The Court noted that Atty. Causing had been disbarred in 2022 in separate cases. Under established doctrine, a lawyer who has already been disbarred cannot again be suspended or disbarred. However, the Court retains jurisdiction over offenses committed while the lawyer was still a member of the Bar.

Applying the CPRA's provisions on multiple offenses and aggravating circumstances, the Court imposed fines of PHP 120,000.00 for the disrespect violation and PHP 35,000.00 for the disobedience violation, totaling PHP 155,000.00. The Court reiterated Atty. Causing's continuing disbarment and ordered the decision attached to his personal record.

Practical Takeaways

• Lawyers must maintain respectful conduct toward courts and their personnel at all times, regardless of the circumstances or how passionate they are about their client's cause.
• Personal attacks on judges in pleadings or other filings can constitute professional misconduct, even if the lawyer believes the allegations are true.
• IBP directives are lawful orders that lawyers must comply with promptly and completely; failure to do so constitutes willful disobedience.
• Disbarment does not erase liability for prior misconduct. The Court can still impose fines for offenses committed before disbarment, which are recorded for consideration in any future reinstatement petition.
• Supporting a client's filing of an administrative case does not automatically constitute promoting a baseless suit, absent clear evidence of malicious purpose.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.