Lawyer Disbarred for Disrespecting Court: Lessons from A.C. No. 11508

The Supreme Court, in Oncines v. Causing (A.C. No. 11508, June 10, 2026), reminded all lawyers that respect for the courts and their personnel is non-negotiable. Even though the respondent lawyer had already been disbarred, the Court still imposed fines for his misconduct, showing that a lawyer's ethical obligations do not simply disappear with disbarment.

The Facts of the Case

The case began when Bernadette Oncines, a court legal researcher at the Regional Trial Court in Butuan City, issued a certification about a land registration case. Atty. Berteni Causing, counsel for a party in that case, demanded that Oncines retract the certification. When she explained she no longer had authority to do so, Causing shouted at her in the presence of her colleagues and threatened to file an administrative case against her.

Causing later endorsed a complaint against Oncines and made baseless accusations of partiality and malice against the presiding judge. He also failed to comply with directives from the Integrated Bar of the Philippines (IBP), including submitting required pleadings and attending mandatory conferences.

The Issue Before the Court

The central question was whether Causing violated the Code of Professional Responsibility and Accountability (CPRA), which took effect in May 2023 and applies to all pending and future cases.

The Court's Ruling

The Supreme Court found Causing guilty of two violations:

First, he violated Canon II, Section 2 of the CPRA, which requires lawyers to respect the courts, their officials, employees, and processes, and to act with courtesy, civility, fairness, and candor. The Court noted that Causing angrily shouted at a court employee and later made slanderous remarks against a judge. While lawyers have the right to criticize judges, this does not give them license to malign or insult the court and its officers.

Second, he violated Canon III, Section 2 for willful disobedience of lawful orders. His failure to comply with IBP directives showed disrespect for the Court's processes.

The Court imposed a fine of PHP 120,000 for the first violation and PHP 35,000 for the second, totaling PHP 155,000. Because Causing had already been disbarred in previous cases, the Court could no longer suspend him. Instead, it recorded the penalties in his file, which would matter if he ever sought reinstatement.

Why This Case Matters

This decision underscores several important principles about lawyer discipline in the Philippines:

Substantial evidence is the standard. In administrative cases against lawyers, complainants must prove their allegations by substantial evidence—evidence that a reasonable mind might accept as adequate. General denials by the respondent lawyer are not enough to rebut well-documented claims.

Prior disciplinary records matter. The Court considered Causing's history of violations, including prior suspensions and disbarment. Under the CPRA, previous administrative liabilities are an aggravating circumstance that can lead to maximum penalties.

Disbarment does not end the Court's jurisdiction. Even after a lawyer is disbarred, the Court can still impose fines for offenses committed while the lawyer was still practicing. This ensures accountability for past misconduct.

Practical Takeaways

• Lawyers must maintain respectful conduct toward courts, judges, and court personnel at all times, regardless of how passionate they are about their client's cause.
• Comply with IBP directives promptly. The IBP acts as the Court's investigating arm, and its orders are not mere requests.
• Criticism of judges has limits. Lawyers may criticize judicial decisions, but personal attacks and baseless accusations of malice are unethical.
• Substantial evidence wins administrative cases. Documentary evidence and witness affidavits carry more weight than general denials.
• A lawyer's disciplinary history follows them. Repeated violations lead to progressively severe penalties, including disbarment.

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