Lawyer's Courtroom Conduct and Disciplinary Liability Under the CPRA

The Supreme Court's recent decision in Oncines v. Causing (A.C. No. 11508, June 10, 2026) provides important guidance on the ethical standards expected of lawyers when dealing with courts and their personnel. The case clarifies how the Code of Professional Responsibility and Accountability (CPRA) applies to lawyer misconduct, including situations where a lawyer has already been disbarred.

The Case Background

The case stemmed from an incident in 2016 at the Regional Trial Court in Butuan City. Atty. Berteni C. Causing, counsel for a party in a land registration case, confronted Bernadette C. Oncines, a court employee who had earlier issued a certification as Officer-in-Charge of the branch clerk of court office.

Atty. Causing angrily shouted at Oncines and demanded she retract the certification she had issued, threatening to file an administrative case against her and have her dismissed from service. When Oncines explained she no longer had authority to retract the document, Atty. Causing endorsed an administrative complaint against her to the Supreme Court.

The Issue Before the Court

The central question was whether Atty. Causing violated the CPRA through his conduct toward the court employee and his subsequent actions, including baseless accusations against the presiding judge.

The Court's Ruling

The Supreme Court found Atty. Causing guilty of two violations under the CPRA, which took effect on May 29, 2023, and applies to all pending and future cases.

First, the Court held that Atty. Causing violated Canon II, Section 2 of the CPRA, which requires lawyers to maintain dignified conduct and respect toward courts, their officials, and employees. The Court emphasized that a lawyer's duty to maintain a respectful attitude toward courts is fundamental to the legal profession. Lawyers must refrain from attributing improper motives to judges without record support.

The Court noted that Atty. Causing's Mandatory Conference Brief contained "blatant yet baseless accusations of partiality and malice" against the presiding judge. Even if such claims were true, the Court stated, they should be raised in the proper forum, not used as personal attacks in unrelated proceedings.

Second, the Court found Atty. Causing liable for willful disobedience of lawful orders for repeatedly failing to comply with Integrated Bar of the Philippines (IBP) directives, including filing his position paper and attending mandatory conferences. This violated Canon III, Section 2 of the CPRA, which requires lawyers to obey the law and promote respect for legal processes.

What Happens When a Lawyer Is Already Disbarred?

A notable aspect of this decision is its treatment of penalties for lawyers who have already been disbarred. The Court noted that Atty. Causing had been disbarred in 2022 and again in 2025 for separate offenses. Once a lawyer is disbarred, no further penalty involving the privilege to practice law can be imposed.

However, the Court clarified that it retains jurisdiction over offenses committed before disbarment. In such cases, the Court may impose fines "for the sole purpose of recording it in his personal file with the Office of the Bar Confidant," which would be considered if the lawyer later seeks reinstatement.

Applying the CPRA's penalty provisions, the Court imposed:

• PHP 120,000.00 fine for failure to maintain respect toward the Court
• PHP 35,000.00 fine for willful noncompliance with IBP directives

The Court also reiterated Atty. Causing's continuing disbarment.

Burden of Proof in Disciplinary Cases

The decision reaffirms that the proper evidentiary standard in disbarment cases is substantial evidence—"the amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion." Complainants must prove their allegations, and mere assumptions or suspicions are insufficient.

In this case, the complainant presented certified documents and witness affidavits, while the respondent offered only general denials without documentary evidence. Notably, the Court found insufficient evidence to support the allegation that Atty. Causing promoted a groundless suit against the complainant, since supporting a client's filing does not necessarily prove malicious purpose.

Practical Takeaways

• Lawyers must maintain respectful conduct toward courts and their personnel at all times, even when passionately advocating for clients. Intemperate language and menacing behavior have no place in the judicial forum.
• Accusations against judges must be raised in proper proceedings, not used as collateral attacks in unrelated cases. Lawyers should refrain from attributing motives to judges without record support.
• IBP directives are lawful orders, not mere requests. Willful noncompliance with IBP rules constitutes disobedience of Supreme Court orders and is a separate disciplinary offense.
• Disbarment does not end the Court's jurisdiction over prior misconduct. The Court may impose fines recorded in the lawyer's file, which can affect future reinstatement petitions.
• Substantial evidence is the standard in disciplinary cases. Complainants should gather documentary evidence and witness statements to support their allegations.

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