Lawyer's Disrespect Toward Court Personnel and IBP Noncompliance: A.C. No. 11508

In a recent administrative case, the Supreme Court En Banc addressed the ethical obligations of lawyers to maintain respect toward courts and their personnel, and to comply with directives from the Integrated Bar of the Philippines (IBP). The case of Oncines v. Atty. Causing (A.C. No. 11508, June 10, 2026) serves as a reminder that a lawyer's duty of courtesy and civility extends to all court officers, and that disobedience of lawful orders—even from the IBP—carries serious consequences.

The Facts of the Case

Complainant Bernadette C. Oncines was a Court Legal Researcher II at Branch 2, Regional Trial Court, Butuan City. In 2014, she was designated as officer-in-charge, Branch Clerk of Court, and in that capacity 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 previously issued. He threatened to file an administrative case against her and insisted she be dismissed from service. When Oncines explained she no longer had authority to retract the Certification, Atty. Causing endorsed an administrative complaint against her to the Court.

Oncines then filed a disbarment 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), which took effect on May 29, 2023 and applies to all pending and future cases.

The Court's Ruling

The Supreme Court found Atty. Causing guilty of violating two provisions of the CPRA:

First, he violated Canon II, Section 2 (Dignified Conduct) for failing to observe and maintain respect toward the Court, its processes, and its employees. The Court emphasized that a lawyer's duty to maintain a respectful attitude toward courts is not for the sake of the temporary incumbent of the judicial office, but for the maintenance of its supreme importance. Atty. Causing's angry shouting at Oncines in the presence of her co-employees, and his baseless accusations of partiality and malice against the presiding judge, demonstrated a lack of reverence for the judiciary.

Second, he violated Canon III, Section 2 (The Responsible and Accountable Lawyer) for willful disobedience of lawful orders. Atty. Causing failed to comply with IBP directives to file his position paper and attend the Mandatory Conference, despite receiving due notice. The Court stressed that IBP directives are not mere requests but lawful orders that must be complied with promptly and completely.

Penalties for Disbarred Lawyers

A notable aspect of this case is that Atty. Causing had already been disbarred in prior cases (Lao v. Atty. Causing, 930 Phil. 538 [2022] and Hidalgo v. Atty. Causing, A.C. No. 11993 [2025]). The Court explained that once a lawyer is disbarred, no further penalty regarding the privilege to practice law can be imposed. However, the Court retains jurisdiction over offenses committed while the lawyer was still a member of the profession. The Court imposed fines—PHP 120,000.00 for the disrespect violation and PHP 35,000.00 for the noncompliance violation—to be recorded in his personal file with the Office of the Bar Confidant, which may be considered if he ever seeks reinstatement.

Practical Takeaways

• Respect is non-negotiable. A lawyer's duty of courtesy and civility extends to all court personnel, not just judges. Intemperate language and menacing behavior have no place in the judicial forum.
• Criticism has limits. While lawyers may criticize judges, this right does not constitute an unbridled license to malign or insult the court and its officers. Personal attacks should be reserved for proper legal fora.
• IBP directives are mandatory. Failure to comply with IBP orders—such as filing position papers or attending conferences—constitutes willful disobedience of lawful orders and is a separate ethical violation.
• Disbarment is not the end. The Court can still impose fines on disbarred lawyers for offenses committed before disbarment, and these are recorded for consideration in any future reinstatement petition.
• Substantial evidence standard. In administrative cases against lawyers, complainants must prove their allegations by substantial evidence—the amount of 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.