Disbarred Lawyer Fined for Defiance and Disrespect of Court Authority

The Supreme Court has ruled that a lawyer's duty to respect the courts does not end even after disbarment. In Oncines v. Causing (A.C. No. 11508, June 10, 2026), the Court imposed fines totaling PHP 155,000 on Atty. Berteni C. Causing for his disrespectful conduct toward a court employee and judge, and for his willful defiance of lawful orders from the Integrated Bar of the Philippines (IBP). While the Court could no longer suspend or disbar an already-disbarred lawyer, it asserted its authority by imposing monetary penalties—a reminder that the Court's disciplinary power over lawyers remains intact.

The Case: A Lawyer's Confrontation with Court Personnel

The case began when Bernadette C. Oncines, a Court Legal Researcher II at the Regional Trial Court of Butuan City, issued a certification in her capacity as officer-in-charge of the branch clerk of court. The certification concerned a land registration case where Atty. Causing served as counsel.

In June 2016, Atty. Causing arrived at the court and angrily shouted at Oncines, demanding that she retract the certification she had issued. He threatened to file an administrative case against her. When Oncines explained she no longer had authority to retract the certification, Atty. Causing endorsed an administrative complaint against her to the Court.

Oncines then filed a disbarment complaint against Atty. Causing, alleging he committed conduct unbecoming of a lawyer. The IBP recommended suspension, but the case took on additional dimensions as Atty. Causing repeatedly failed to comply with IBP directives.

The Issue: Violations of the Code of Professional Responsibility and Accountability

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 all pending cases.

The Court found Atty. Causing guilty of two violations: failing to maintain respect toward the courts and judicial officers, and willfully disobeying lawful orders of the Supreme Court and the IBP.

The Ruling: Fines Despite Prior Disbarment

The Court noted that Atty. Causing had a history of disciplinary infractions. He was previously suspended for one year in Velasco v. Causing for breaching confidentiality, and disbarred in Lao v. Causing (2022) and Hidalgo v. Causing (2025) for defamatory conduct.

Because Atty. Causing was already disbarred, the Court could not impose further suspension or disbarment. However, the Court emphasized it retains jurisdiction over offenses committed while the lawyer was still a member of the profession. The CPRA expressly allows the Court to impose a fine upon a disbarred lawyer when subsequently found guilty of a new charge.

The Court imposed:

• PHP 120,000 for violating Canon II, Section 2 of the CPRA (failure to maintain respect toward the Court and its employees), classified as a serious offense
• PHP 35,000 for violating Canon III, Section 2 (willful disobedience of lawful orders), classified as a less serious offense

Why the Conduct Was Unacceptable

The Court emphasized that lawyers owe a sworn duty to maintain a respectful attitude toward courts—not for the sake of the judge, but for the maintenance of the judiciary's supreme importance. Atty. Causing's angry shouting at a court employee, his baseless accusations of partiality against the presiding judge, and his slanderous remarks demonstrated a lack of reverence for the judicial system.

The Court also stressed that lawyers must obey IBP directives as lawful orders, not mere requests. Atty. Causing's failure to file his position paper and attend the mandatory conference showed cavalier disregard for disciplinary processes.

Practical Takeaways

• Respect for courts is non-negotiable. Lawyers must display courtesy and civility toward judges, court personnel, and processes—even when advocating vigorously for clients.
• Disbarment does not end disciplinary exposure. The Court can still impose fines for offenses committed before disbarment, and these are recorded for consideration in any future reinstatement petition.
• IBP directives are lawful orders. Failure to comply with IBP requirements in disciplinary proceedings constitutes willful disobedience of the Supreme Court.
• Criticism of judges has limits. Lawyers may critique judicial decisions, but personal attacks and baseless accusations of bias or malice are sanctionable.
• Prior infractions aggravate penalties. A history of disciplinary violations will result in maximum penalties under the CPRA.

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