G.R. No. L-37650 February 28, 1974
Visayan Stevedore Transportation Company (Hinigaran Branch) and Rafael Xaudaro, petitioners, vs. Court of Industrial Relations and United Workers and Farmers’ Association (UWFA), Venancio Dano-og and Buenaventura Agarcio and 137 Others, respondents, Atty. Jose K. Manguiat, Jr., respondent.

FACTS

This case originated from a petition for review on certiorari filed by Visayan Stevedore Transportation Company. The Supreme Court, without giving due course to the petition, required the respondents to file a comment. Atty. Jose K. Manguiat, Jr., identifying himself as counsel for the respondent Court of Industrial Relations, filed a motion for a thirty-day extension to file the comment, which was granted. However, no comment was filed by the expiration of the extended period. Consequently, the Court issued another resolution requiring Atty. Manguiat to file the comment and explain his failure to do so.
In response, Atty. Manguiat filed a terse two-page “manifestation and comment.” For his failure to file on time, he explained that he had requested another lawyer in his office, Atty. Mariano Capanas, to prepare the comment, and he thought in good faith that it had been filed. The submitted comment itself was perfunctory, merely asserting that the CIR’s resolution was in accordance with law and evidence and citing the doctrine on the conclusiveness of factual findings by the CIR without addressing the specific legal issues raised in the petition.

ISSUE

Whether Atty. Jose K. Manguiat, Jr. is administratively liable for his failure to comply with the Supreme Court’s directives and for submitting an inadequate comment.

RULING

Yes, Atty. Manguiat is administratively liable and is hereby reprimanded. The Court found his explanation for the delay unsatisfactory. Delegating the task of preparing the comment by a mere request to a colleague did not absolve him of his personal duty to comply with the Court’s order. His alleged good-faith belief that the comment had been filed does not justify the omission; at the very least, he should have sought another extension if he was unable to meet the deadline. This failure constituted a neglect of duty.
Furthermore, the comment he eventually submitted was deemed grossly insufficient. It failed to address the principal legal questions presented in the petition, offering only a dogmatic and conclusory statement about the binding nature of the CIR’s factual findings. The Court emphasized that a comment required by the Supreme Court must engage with the legal arguments raised, not merely restate general doctrines. The pontifical tone of the skimpy comment, displaying a lack of the “becoming modesty” expected of officers of the court, compounded his infraction. The Court held that such conduct fell short of the diligence and respect required from a member of the Bar.