Lawyer Fined for Shouting at Court Employee and Defying IBP Orders

The Supreme Court, in a June 10, 2026 en banc decision, fined a lawyer P155,000 for berating a court employee and repeatedly ignoring orders from the Integrated Bar of the Philippines (IBP). The case of Oncines v. Causing (A.C. No. 11508) also clarifies an important point: a lawyer who has already been disbarred can still be fined for misconduct committed before the disbarment.

The Facts of the Case

The dispute began in 2014 when Bernadette Oncines, a Court Legal Researcher at the Regional Trial Court in Butuan City, issued a certification about a land registration case. Atty. Berteni Causing, counsel for a party in that case, later demanded that Oncines retract the certification.

In June 2016, Atty. Causing went to the court and angrily shouted at Oncines, demanding she withdraw the document. He threatened to file an administrative case against her and insisted she be dismissed from service. When Oncines explained she no longer had authority to retract the certification, Atty. Causing endorsed an administrative complaint against her.

Oncines then filed a disbarment complaint against Atty. Causing, alleging he violated the Code of Professional Responsibility by his conduct.

The Issue

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

The Ruling

The Court found Atty. Causing guilty of two violations. First, he breached Canon II, Section 2 of the CPRA, which requires lawyers to act with courtesy and civility toward courts and their employees. The Court noted that shouting at a court employee and demanding she explain her actions showed a lack of respect for the judiciary.

Second, he violated Canon III, Section 2 for willfully disobeying lawful orders. Atty. Causing failed to file his position paper and attend mandatory conferences before the IBP despite receiving due notice.

However, the Court found insufficient evidence that Atty. Causing promoted a groundless suit against Oncines. While he supported his client's complaint, the Court said this did not clearly prove malicious intent.

Penalties for a Disbarred Lawyer

A notable aspect of the ruling is that Atty. Causing had already been disbarred in 2022 for separate offenses. The Court explained that once a lawyer is disbarred, no further suspension or disbarment can be imposed. However, the Court retains jurisdiction over offenses committed before disbarment.

The Court imposed a P120,000 fine for the disrespectful conduct and a P35,000 fine for the IBP noncompliance, totaling P155,000. The fines were increased due to Atty. Causing's prior administrative liabilities as an aggravating circumstance. The decision was attached to his personal record and may be considered if he ever seeks reinstatement.

Practical Takeaways

• Respect for court personnel is mandatory. Lawyers must treat court employees with courtesy, regardless of frustration with a case. Shouting or making demands of court staff can constitute professional misconduct.
• IBP directives are court orders. The IBP acts as the Supreme Court's investigating arm. Ignoring its directives is treated as disobedience of the Court itself.
• Disbarment does not end jurisdiction. A disbarred lawyer can still be penalized for earlier misconduct, and the penalty is recorded for possible reinstatement proceedings.
• Criticism of judges has limits. Lawyers may criticize judges, but personal attacks and baseless accusations of bias are sanctionable.
• The CPRA applies retroactively. The new Code of Professional Responsibility and Accountability governs conduct in cases pending when it took effect.

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