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MANUEL E. CONTRERAS v. ATTY. FREDDIE A. VENIDA

FACTS:

The case involves a complaint filed by Judge Manuel E. Contreras against Atty. Freddie A. Venida. Judge Contreras alleged that Atty. Venida engaged in dilatory tactics, abused the court's processes, and filed impertinent motions and manifestations that obstructed the administration of justice. Atty. Venida was also accused of being defiant, recalcitrant, and belligerent towards the authority of the court. Due to the delays caused by Atty. Venida's actions, Judge Contreras suspended him as counsel and recommended that he undergo a neuro-psychiatric examination to determine his fitness to practice law and stand trial. The Integrated Bar of the Philippines (IBP) found Judge Contreras' recommendation well taken and recommended that Atty. Venida be suspended pending the examination. The IBP Board of Governors passed a resolution indefinitely suspending Atty. Venida. The Supreme Court then required Atty. Venida to undergo a neuro-psychiatric examination, which was conducted in 2003 and the evaluation report was submitted. However, Atty. Venida's whereabouts became unknown, and various attempts were made to locate him. The case records were returned to the Court, and the National Center for Mental Health was directed to provide the medical records of Atty. Venida. The Court also granted the Supreme Court Medical and Dental Services the authority to summon individuals who can provide collateral information on Atty. Venida's condition. Various reports were submitted regarding the search for Atty. Venida, but his current address remained unknown. The case was still pending as of the most recent resolution in 2016.

ISSUES:

  1. Whether or not Atty. Freddie A. Venida should undergo a neuro-psychiatric examination to determine his fitness to engage in the practice of law and his competency to stand trial.

RULING:

  1. Atty. Freddie A. Venida is ordered to undergo a neuro-psychiatric examination to determine his fitness to engage in the practice of law and his competency to stand trial.

PRINCIPLES:

  • The court has the authority to order a lawyer to undergo a neuro-psychiatric examination to determine his fitness to engage in the practice of law and his competency to stand trial.

  • Abuse of court processes and employing dilatory tactics can be grounds for disciplinary action against a lawyer.

  • Offensive, disrespectful, and defiant language in pleadings can be grounds for disciplinary action against a lawyer.

  • Appearance and conduct inconsistent with the standards expected from an officer of the court and a member of the Bar can be grounds for disciplinary action against a lawyer.

  • The Integrated Bar of the Philippines (IBP) has the authority to recommend the suspension of a lawyer pending the results of a neuro-psychiatric examination.

  • The Supreme Court has the authority to indefinitely suspend a lawyer based on the recommendation of the IBP.

  • The Supreme Court can require a lawyer to submit to a neuro-psychiatric examination conducted by the Supreme Court Clinic.

  • The Supreme Court can require the submission of collateral information and medical records to aid in the determination of a lawyer's fitness to practice law.