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

The Supreme Court has ruled that a lawyer who shouted at court personnel, made baseless accusations against a judge, and ignored orders from the Integrated Bar of the Philippines (IBP) violated the Code of Professional Responsibility and Accountability (CPRA). In Oncines v. Causing (A.C. No. 11508, June 10, 2026), the Court imposed fines totaling PHP 155,000 on Atty. Berteni C. Causing—even though he had already been disbarred—demonstrating that lawyers remain accountable for misconduct committed while they still held their license.

The Facts of the Case

The case arose from a 2014 incident at the Regional Trial Court in Butuan City. Complainant Bernadette Oncines, a court legal researcher, had issued a certification about a parcel of land involved in a cadastral case. Two years later, Atty. Causing, who represented a party in that case, arrived at the court and angrily shouted at Oncines, demanding that she retract the certification. He threatened to file an administrative case against her and have her dismissed from service.

Atty. Causing later endorsed an administrative complaint against Oncines. She responded by filing a disbarment complaint against him, alleging that he promoted a groundless suit and committed conduct unbecoming of a lawyer.

The Issue

The central question was whether Atty. Causing violated the CPRA through his conduct toward court personnel, his accusations against the presiding judge, and his failure to comply with IBP directives.

The Ruling

The Supreme Court found Atty. Causing guilty of two violations.

First, he violated Canon II, Section 2 of the CPRA, which requires lawyers to respect the courts and act with courtesy and civility. The Court noted that Atty. Causing cast doubt on the court's authority when he shouted at Oncines in front of colleagues. His Mandatory Conference Brief also contained blatant yet baseless accusations of partiality and malice against Judge Emmanuel Escatron. While lawyers may criticize judges, the Court emphasized 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 for willfully disobeying lawful orders. Atty. Causing failed to attend the mandatory conference and file his position paper with the IBP, despite receiving due notice. The Court stressed that IBP directives are not mere requests but lawful orders which should be complied with promptly and completely.

However, the Court found insufficient evidence that Atty. Causing promoted a frivolous or baseless suit against Oncines. Supporting a client's complaint, even if aggressive, did not clearly prove malicious intent.

Penalties Imposed

Because Atty. Causing had prior disciplinary records—including disbarment in two earlier cases—the Court treated his prior liabilities as an aggravating circumstance. Under the CPRA, this warranted the maximum penalty for each offense.

The Court imposed:

• PHP 120,000 for disrespecting the Court and its employees
• PHP 35,000 for disobeying IBP directives

Since Atty. Causing was already disbarred, the Court could no longer suspend him. Instead, it imposed fines for the sole purpose of recording them in his file with the Office of the Bar Confidant, to be considered if he ever seeks reinstatement. The Court reiterated his continuing disbarment.

Practical Takeaways

• Respect is non-negotiable. Lawyers must maintain a respectful attitude toward courts and their personnel, regardless of how passionately they advocate for clients.
• Criticism has limits. Lawyers may criticize judges, but accusations must have factual or legal basis and should be raised in the proper forum—not in pleadings as personal attacks.
• IBP orders are court orders. Failure to comply with IBP directives in disciplinary proceedings constitutes willful disobedience and is itself a punishable offense.
• Disbarment is not the end. A disbarred lawyer can still be fined for misconduct committed before disbarment, and the record will affect any future petition for reinstatement.
• Prior offenses matter. Repeated violations of the CPRA trigger aggravating circumstances that increase penalties.

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