Lawyers Must Respect Courts and Their Staff: Lessons from A.C. No. 11508

The Supreme Court has repeatedly emphasized that lawyers owe respect not only to judges but also to court personnel. In Oncines v. Causing (A.C. No. 11508, June 10, 2026), the Court imposed fines on a lawyer who shouted at a court employee, demanded the retraction of an official certification, and made baseless accusations against a judge. Although the respondent had already been disbarred in earlier cases, the Court still asserted its disciplinary authority over his prior misconduct.

The Facts of the Case

The complainant, Bernadette C. Oncines, was a Court Legal Researcher II and later officer-in-charge of Branch 2, Regional Trial Court, Butuan City. In October 2014, she issued a certification regarding a land registration case involving Lot No. 447.

In June 2016, Atty. Berteni C. Causing, counsel for a party in that case, arrived at the court and angrily shouted at Oncines. He demanded that she retract her 2014 certification and threatened to file an administrative case against her if she refused. When Oncines explained she no longer had authority to retract the document, Atty. Causing endorsed a complaint against her to the Supreme Court.

Oncines then filed her own administrative complaint against Atty. Causing for conduct unbecoming of a lawyer.

The Issue

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

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 pending cases.

First, violation of Canon II, Section 2 (dignified conduct). The Court held that a lawyer must maintain a respectful attitude toward courts and judicial officers. Atty. Causing's angry shouting at Oncines in front of her colleagues showed disrespect for the court's authority. His Mandatory Conference Brief also contained baseless accusations of partiality and malice against the presiding judge. The Court reminded lawyers that the right to criticize judges does not include license to malign them.

Second, violation of Canon III, Section 2 (responsible and accountable lawyer). Atty. Causing failed to file his position paper and attend the mandatory conference before the IBP's Commission on Bar Discipline. The Court treated this as willful disobedience of lawful orders.

However, the Court did not find substantial evidence that Atty. Causing promoted a groundless suit against Oncines. While he supported his client's complaint, the Court found insufficient proof of malicious intent.

Penalties Imposed

Because Atty. Causing had already been disbarred in Lao v. Causing (2022) and Hidalgo v. Causing (2025), the Court could not impose another suspension or disbarment. Instead, it imposed fines:

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

The Court reiterated his continuing disbarment and ordered the decision attached to his personal record for consideration in any future petition for reinstatement.

Practical Takeaways

• Respect extends to court staff. A lawyer's duty of respect covers judges, court employees, and processes—not just the bench itself.
• Threats and intimidation have consequences. Demanding that a court employee retract an official document, especially through shouting and threats, constitutes grossly undignified conduct.
• Comply with IBP directives. The IBP is the Court's investigating arm. Ignoring its orders amounts to disobeying the Supreme Court itself.
• Criticism has limits. Lawyers may criticize judges, but accusations must have basis in the record and be raised in proper forums.
• Disbarment does not erase prior misconduct. The Court retains jurisdiction over offenses committed before disbarment and may impose fines recorded in the lawyer's file.

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