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MARIBETH RODRIGUEZ-MANAHAN v. ATTY. RODOLFO FLORES

FACTS:

The case involves a disciplinary action filed against Atty. Rodolfo Flores (Atty. Flores) for his unethical behavior and misconduct during the proceedings in Civil Case No. 1863 before the Municipal Trial Court of San Mateo, Rizal. Judge Maribeth Rodriguez-Manahan (Judge Manahan) issued an order inhibiting herself from the case and referred the matter to the Bar Discipline Committee and the Supreme Court for investigation and sanction. The Office of the Bar Confidant treated Judge Manahan's order as a formal administrative complaint against Atty. Flores and referred the case to the Executive Judge of the Regional Trial Court of Rizal. Investigating Judge Josephine Zarate Fernandez found that Atty. Flores had failed to comply with court orders, failed to submit proof of Mandatory Continuing Legal Education (MCLE) compliance, and used intemperate language in his pleadings. The Investigating Judge recommended a one-year suspension for Atty. Flores. However, the Supreme Court found a fine of P5,000.00 more appropriate due to the respondent's age and lack of prior infractions. The Court reminded Atty. Flores to be more circumspect in his actions and to respect court processes.

ISSUES:

  1. Whether Atty. Rodolfo Flores should be held liable for failing to obey the trial court's order to submit proof of his MCLE compliance.

  2. Whether Atty. Rodolfo Flores should be held liable for employing intemperate language in his pleadings.

RULING:

  1. Yes, Atty. Rodolfo Flores should be held liable for failing to obey the trial court's order to submit proof of his MCLE compliance. He was given several opportunities to comply but failed to do so. As an officer of the court, he is expected to respect court orders and failure to do so disrespects the judicial branch of the government.

  2. Yes, Atty. Rodolfo Flores should be held liable for employing intemperate language in his pleadings. Rule 11.03, Canon 11 of the Code of Professional Responsibility requires attorneys to abstain from scandalous, offensive, or menacing language or behavior before the courts. Atty. Flores' use of intemperate language violates this rule.

PRINCIPLES:

  • Court orders are to be respected to maintain the authority and integrity of the judicial branch.

  • Attorneys are expected to use circumspect language in their pleadings.

  • Attorneys are entitled to voice their criticism within the bounds of the constitutional guarantee of freedom of speech.

  • Attorneys owe absolute fidelity to their client's cause but must act within the bounds of the law and the orderly administration of justice.