Lawyer's Courtroom Bullying and Defiance of IBP Orders Draw PHP 155,000 Fine

The Supreme Court, in a June 10, 2026 en banc decision, fined a lawyer PHP 155,000 for berating a court employee and defying orders of the Integrated Bar of the Philippines (IBP). The case, Oncines v. Causing (A.C. No. 11508), serves as a reminder that lawyers must maintain respect for the courts and their personnel, even when zealously advocating for clients.

The Incident at RTC Butuan

The case arose from a 2016 incident at Branch 2 of the Regional Trial Court in Butuan City. Complainant Bernadette C. Oncines, a Court Legal Researcher II, had earlier issued a certification about a land registration case while serving as officer-in-charge of the branch.

When respondent Atty. Berteni C. Causing, counsel for a party in that case, arrived at the court, he angrily shouted at Oncines. He demanded she retract the certification she had previously issued and threatened to file an administrative case against her and have her dismissed from service. Oncines' co-employees witnessed the outburst and corroborated her account.

Atty. Causing later endorsed his client's administrative complaint against Oncines to the Court. In response, Oncines filed a disbarment complaint against Atty. Causing.

The Standard of Evidence

The Court reiterated that administrative cases against lawyers require only substantial evidence—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The complainant must prove allegations by substantial evidence; mere assumptions and suspicions will not suffice.

Here, Oncines successfully presented certified true copies of documents and witness affidavits. Atty. Causing, by contrast, offered only general denials and failed to submit any documentary evidence or witness affidavits. He also failed to file his position paper with the IBP's Commission on Bar Discipline.

Violations Under the CPRA

The Court found Atty. Causing guilty of two violations under the Code of Professional Responsibility and Accountability (CPRA), which took effect on May 29, 2023:

First, he violated Canon II, Section 2 (dignified conduct) by shouting at Oncines and by making baseless accusations of partiality and malice against the presiding judge in his pleadings. The Court stressed that while lawyers may criticize judges, this right does not include an unbridled license to malign court officers.

Second, he violated Canon III, Section 2 (responsible and accountable lawyer) by willfully disobeying IBP directives, including failing to attend mandatory conferences and file required pleadings. The Court emphasized that IBP directives are lawful orders, not mere requests.

Penalty for a Disbarred Lawyer

Notably, Atty. Causing had already been disbarred in 2022 in a separate case. 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 and may impose fines, which are recorded in the lawyer's file and considered should the lawyer seek reinstatement.

Considering the aggravating circumstance of prior administrative liabilities, the Court imposed the maximum fines: PHP 120,000 for the Canon II violation and PHP 35,000 for the Canon III violation, totaling PHP 155,000.

Practical Takeaways

• Respect for court personnel is non-negotiable. Lawyers must treat judges, clerks, and court staff with courtesy and civility, regardless of frustration with a case.
• Criticism of judges has limits. Lawyers may question judicial rulings through proper channels, but personal attacks or baseless imputations of bias are sanctionable.
• IBP directives are binding. Failure to comply with IBP orders in disciplinary proceedings constitutes willful disobedience of the Supreme Court's lawful orders.
• Disbarment does not end accountability. A disbarred lawyer can still be fined for offenses committed before disbarment, and the record may affect future reinstatement petitions.
• Substantial evidence cuts both ways. Complainants must present real evidence; respondents who offer only denials risk adverse findings.

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