Lawyer Fined P155,000 for Disrespecting Court and Defying IBP Orders

The Supreme Court, in a June 10, 2026 en banc decision (A.C. No. 11508), imposed fines totaling PHP 155,000.00 on a lawyer who had already been disbarred, for misconduct committed while he was still a member of the Bar. The case reminds lawyers that the Court retains jurisdiction to discipline acts committed before disbarment, and that respect for the judiciary and obedience to lawful orders are non-negotiable duties.

The Facts

The case arose from a 2016 incident at the Regional Trial Court, Branch 2, in Butuan City. Complainant Bernadette C. Oncines, a court employee, had earlier issued a certification about a land registration case while serving as officer-in-charge of the branch. Years later, the respondent lawyer, Atty. Berteni C. Causing, who represented a party in that case, demanded that Oncines retract the certification—even though she no longer held that position.

When Oncines declined, Atty. Causing shouted at her angrily in the presence of her client and court staff, demanded a retraction, and threatened to file an administrative case against her. He later endorsed his client's administrative complaint against Oncines to the Court.

The Issue

The central question was whether Atty. Causing violated the Code of Professional Responsibility and Accountability (CPRA), which took effect on May 29, 2023, and applies to pending cases.

The Ruling

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

First, he violated Canon II, Section 2 (dignified conduct) by failing to observe and maintain respect toward the Court, its processes, and its employees. The Court noted that his angry outburst at a court employee, his baseless accusations of partiality against the presiding judge, and his slanderous remarks about a judge in other pleadings showed a lack of reverence for the judiciary. While lawyers may criticize judges, the Court stressed that this right "does not constitute an unbridled license to malign and insult the court and its officers."

Second, he violated Canon III, Section 2 (responsible and accountable lawyer) for willful disobedience of lawful orders. Atty. Causing repeatedly failed to comply with directives of the Integrated Bar of the Philippines (IBP), including attending mandatory conferences and filing required pleadings. The Court emphasized that IBP directives are "not mere requests but lawful orders which should be complied with promptly and completely."

The Court, however, rejected the allegation that Atty. Causing promoted a groundless suit against Oncines. While his conduct supported his client's complaint, the evidence did not clearly establish malicious intent.

Penalty Despite Disbarment

A key aspect of the ruling: Atty. Causing had already been disbarred in 2022 for separate offenses. The Court explained that while it can no longer suspend or disbar an already-disbarred lawyer, it retains jurisdiction over offenses committed before disbarment. It imposed fines instead—PHP 120,000.00 for the disrespect violation and PHP 35,000.00 for the disobedience violation—to be recorded in his file with the Office of the Bar Confidant. These amounts reflect the maximum penalties, given the aggravating circumstance of his prior administrative liabilities.

Practical Takeaways

• Respect for the judiciary is a core duty. Lawyers must treat court officials and employees with courtesy and civility, regardless of frustration with a case.
• Personal attacks on judges have consequences. Accusations of bias or malice must be raised in the proper forum with factual support—not in pleadings as rhetorical weapons.
• IBP directives are court orders. Failure to comply with the IBP's lawful directives, such as attending conferences or filing position papers, constitutes willful disobedience.
• Disbarment does not erase prior misconduct. The Court can still impose fines and record penalties against a disbarred lawyer for offenses committed before disbarment, which may affect future reinstatement petitions.
• Evidence matters. In disbarment cases, complainants must prove their allegations by substantial evidence; respondents who merely deny without presenting contrary proof risk adverse findings.

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