FACTS:

The facts of the case are undisputed. On July 31, 1987, the Republic of the Philippines, through the Presidential Commission on Good Government (PCGG), filed a complaint before the Sandiganbayan against Eduardo M. Cojuangco, Jr., among others, for the recovery of alleged ill-gotten wealth, including shares of stocks in various corporations in PCGG Case No. 33. Among the defendants named were petitioners Teodoro Regala, Edgardo J. Angara, Avelino V. Cruz, Jose C. Concepcion, Rogelio A. Vinluan, Victor P. Lazatin, Eduardo U. Escueta, Paraja G. Hayudini, and private respondent Raul S. Roco, who were partners at the Angara, Abello, Concepcion, Regala and Cruz Law Offices (ACCRA Law Firm). The ACCRA Law Firm had performed legal services for its clients, which included the organization and acquisition of business associations, with its members sometimes acting as incorporators or stockholders. In these capacities, they handled documents substantiating the client's equity holdings and gained information about their clients' assets and personal/business affairs. The named petitioners and private respondent Roco admitted assisting in the organization and acquisition of the companies involved in Civil Case No. 0033. Following a PCGG motion dated August 20, 1991, private respondent Roco was excluded from the complaint under the understanding that he would reveal the identity of the principals for whom he acted as nominee/stockholder. On October 8, 1991, petitioners filed a counter-motion seeking the same treatment (exclusion as parties-defendants) accorded to Roco, accompanied by their opposition to the PCGG’s conditions which required disclosure of client identities, submission of relevant documents and deeds of assignment. However, evidence from the proceedings suggested that Roco had not actually undertaken or revealed his client's identity, contrary to the basis cited for his exclusion. Consequently, the Sandiganbayan denied petitioners' request for exclusion from the complaint due to their refusal to comply with the PCGG’s conditions until they disclosed their clients' identities.

ISSUES:

1. Whether petitioners ACCRA lawyers can be compelled to disclose the identity of their clients under the circumstances of the case.

2. Whether there was a violation of the equal protection clause when PCGG excluded Raul Roco from the list of party-defendants while retaining the petitioners without substantial distinctions.

RULING:

1. Compulsion to Disclose Client Identity

   The Supreme Court ruled that petitioners ACCRA lawyers cannot be compelled to disclose the identity of their clients under the circumstances of the case. The Court recognized the lawyer-client confidentiality privilege as applicable, protecting the attorneys from revealing their clients' identities. The Court found that the scenario fell within the exceptions to the general rule that client identity is not privileged, emphasizing that disclosing the names of clients here would implicate them in the very activities for which legal advice was sought (the alleged accumulation of ill-gotten wealth).

2. Equal Protection Clause Violation

   The Supreme Court found that the exclusion of private respondent Raul Roco from the third amended complaint violated the equal protection clause, as there was no substantial proof that he revealed the identity of his clients, an act purportedly used to justify his exclusion. The petitioners were found to be similarly situated as Roco, and thus should be accorded the same treatment, leading to the order for their exclusion as party-defendants in the case.

PRINCIPLES:

• Attorney-Client Privilege

  Lawyers owe a fiduciary duty to their clients to maintain the confidentiality of the information obtained during the lawyer-client relationship, which extends to refusing to disclose client identity when disclosure implicates the client in the activities for which legal advice was sought.

• Equal Protection Clause

  The equal protection clause mandates that all persons similarly situated should be treated alike both regarding privileges granted and liabilities imposed. Uneven application of legal norms violates this constitutional guarantee.