Lawyer's Courtroom Conduct: Disbarred Attorney Fined PHP 155,000 for Disrespect

The Supreme Court recently reminded all lawyers that respect for the courts and their personnel is a non-negotiable duty—one that continues to be enforced even after a lawyer has been disbarred. In Oncines v. Atty. Causing (A.C. No. 11508, June 10, 2026), the Court imposed fines totaling PHP 155,000 on a disbarred attorney for his disrespectful conduct toward a court employee and his willful disobedience of Integrated Bar of the Philippines (IBP) directives. The case clarifies an important point: disbarment does not erase liability for misconduct committed while the lawyer was still practicing.

The Facts of the Case

The dispute began when Bernadette C. Oncines, a Court Legal Researcher at the Regional Trial Court of Butuan City, issued a certification in October 2014 regarding a land registration case. The certification stated that a certain lot appeared to be the subject of a pending cadastral case.

Two years later, in June 2016, Atty. Berteni C. Causing—counsel for a party in that land case—arrived at the court and angrily shouted at Oncines. He demanded that she retract the certification she had previously issued and threatened to file an administrative case against her if she refused. When Oncines explained she no longer had authority to act on the matter, Atty. Causing endorsed an administrative complaint against her to the Supreme Court.

Oncines subsequently filed a disbarment complaint against Atty. Causing, alleging that he promoted a malicious and unfounded suit against her and engaged in conduct unbecoming of a lawyer.

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 all pending and future cases.

The Court's Ruling

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

First, he failed to maintain respect toward the courts and their employees. The Court emphasized that a lawyer's duty to maintain a respectful attitude toward the courts is fundamental. The CPRA requires lawyers to respect the law, the courts, tribunals and other government agencies, their officials, employees and processes, and to act with courtesy, civility, fairness, and candor toward fellow members of the bar.

Atty. Causing's angry shouting at Oncines in the presence of others, coupled with his baseless accusations of partiality and malice against the presiding judge, fell far short of this standard. The Court noted that while lawyers have the right to criticize judges, this right "does not constitute an unbridled license to malign and insult the court and its officers."

Second, he willfully disobeyed lawful directives. Atty. Causing repeatedly failed to comply with IBP orders to file his position paper and attend the mandatory conference. The Court stressed that IBP directives are not mere requests but lawful orders that lawyers must comply with promptly and completely.

Penalties After Disbarment

A notable aspect of this case is that Atty. Causing had already been disbarred in 2022 for separate offenses involving social media posts. The Court explained that once a lawyer is disbarred, no further penalty can be imposed regarding the privilege to practice law. However, the Court retains jurisdiction over offenses committed before disbarment.

The Court imposed fines of PHP 120,000 for the disrespect violation and PHP 35,000 for the disobedience violation, totaling PHP 155,000. These penalties were recorded in Atty. Causing's personal file with the Office of the Bar Confidant and may be considered if he ever petitions for reinstatement.

Practical Takeaways

• Respect is mandatory, not optional. Lawyers must maintain courtesy and civility toward courts, judges, and court personnel—even when advocating vigorously for clients.
• Criticism has limits. Lawyers may criticize judicial decisions, but personal attacks and baseless accusations of bias against judges are professional misconduct.
• IBP directives are binding. Failure to comply with IBP orders in disciplinary proceedings constitutes willful disobedience of the Supreme Court's lawful orders.
• Disbarment is not a shield. A disbarred lawyer can still be penalized for misconduct committed before disbarment, with fines recorded for future reinstatement consideration.
• Groundless suits require proof. Merely supporting a client's complaint does not automatically constitute promoting a frivolous suit absent clear evidence of malicious intent.

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