Lawyer Fined for Shouting at Court Staff and Defying IBP Orders

The Supreme Court, in Oncines v. Causing (A.C. No. 11508, June 10, 2026), imposed fines totaling PHP 155,000 on a lawyer who shouted at a court employee, demanded she retract an official certification, and later defied orders of the Integrated Bar of the Philippines (IBP). The case underscores that lawyers must maintain respect toward courts and their personnel, and that disobedience of lawful directives carries serious consequences.

The Facts

Complainant Bernadette C. Oncines was a Court Legal Researcher II at Branch 2, Regional Trial Court, Butuan City. In 2014, while serving as officer-in-charge of the branch clerk of court, she issued a certification regarding Lot No. 447, which was the subject of a land registration case where respondent Atty. Berteni C. 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. Oncines reported the incident to the presiding judge and later filed a disbarment complaint against Atty. Causing.

The Issue

The central question was whether Atty. Causing violated the Code of Professional Responsibility and Accountability (CPRA) by his conduct toward court personnel and his failure to comply with IBP directives.

The Ruling

The Court found Atty. Causing guilty of two violations under the CPRA. First, he violated Canon II, Section 2, which requires lawyers to maintain dignified conduct and act with courtesy, civility, fairness, and candor toward courts, their officials, and employees. His angry outburst and demand that Oncines retract the certification showed a lack of respect for the court's processes.

Second, he violated Canon III, Section 2 for willful disobedience of lawful orders. Atty. Causing repeatedly failed to comply with IBP directives to file his position paper and attend the mandatory conference, despite receiving due notice.

The Court rejected the allegation that Atty. Causing promoted a groundless suit against Oncines, finding insufficient evidence of malicious intent. However, the Court noted his prior disciplinary record, including disbarment in Lao v. Causing (A.C. No. 11508, 2022) and Hidalgo v. Causing (A.C. No. 11993, March 4, 2025).

Because Atty. Causing had already been disbarred, the Court could no longer impose suspension or disbarment. Instead, it imposed fines: PHP 120,000 for disrespect toward the Court and PHP 35,000 for noncompliance with IBP directives, to be recorded in his personal file with the Office of the Bar Confidant.

Practical Takeaways

• Respect is non-negotiable. Lawyers must treat court personnel with courtesy and civility, regardless of disagreements with their actions. Shouting at or intimidating court employees violates ethical standards.
• Disobeying IBP orders is disobedience of the Court. The IBP acts as the Court's investigating arm in disciplinary cases. Ignoring its directives constitutes willful disobedience of lawful orders.
• Disbarment does not end accountability. The Court retains jurisdiction over offenses committed before disbarment and may impose fines to be recorded for consideration in any future reinstatement petition.
• Criticism has limits. While lawyers may criticize judges, they cannot malign or insult them with baseless accusations of partiality or malice.
• Substantial evidence standard applies. Complainants in disbarment cases must prove their allegations by substantial evidence—relevant evidence that a reasonable mind might accept as adequate to justify a conclusion.

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