A.C. No. 10204. September 14, 2020
Judge Rosemarie V. Ramos, Regional Trial Court, Branch 19, Bangui, Ilocos Norte, Complainant, vs. Atty. Vicentito M. Lazo, Respondent.
FACTS
Complainant Judge Rosemarie V. Ramos filed a disbarment complaint against respondent Atty. Vicentito M. Lazo, a member of the Sangguniang Panlalawigan of Ilocos Norte. The complaint stemmed from two privilege speeches delivered by Atty. Lazo before the provincial board in September 2013. In his first speech, he referenced a pending criminal case before Judge Ramos, stating she had inhibited herself due to a report that she received two million pesos for an acquittal. He urged her to inhibit and implored the board to monitor the case to prevent money from changing hands. In his second speech, concerning a drug case decided by Judge Ramos, he intimated something “fishy” about the acquittal, theorizing it was due to her personal bias, and mentioned rumors of “justice for sale” in her sala. Media was present during both sessions.
The Integrated Bar of the Philippines (IBP) Investigating Commissioner found Atty. Lazo liable, recommending a one-year suspension for violating the Code of Professional Responsibility (CPR) by publicly imputing motives to a judge without basis and undermining confidence in the judiciary. However, the IBP Board of Governors reversed this, dismissing the complaint. The Board reasoned that Atty. Lazo, as a provincial board member, was within his rights to deliver a privileged speech, and the media presence was incidental as sessions were open to the public.
ISSUE
Whether or not Atty. Lazo is administratively liable for violating Canons and Rules of the Code of Professional Responsibility.
RULING
Yes, the Supreme Court found Atty. Lazo administratively liable and suspended him from the practice of law for one year. The Court reversed the IBP Board’s dismissal. The legal logic centers on a lawyer’s paramount duty as an officer of the court to uphold its dignity and authority. While Atty. Lazo spoke in his capacity as a public official, he never ceased to be a lawyer bound by the CPR. Canon 1 and Rule 1.02 require a lawyer to promote respect for legal processes and not engage in acts lessening confidence in the legal system. Canon 11 mandates that a lawyer shall observe and maintain respect due to the courts.
The Court held that Atty. Lazo’s speeches, which accused Judge Ramos of bribery and bias based on rumors and unsupported speculation, directly attacked her integrity and the judiciary’s honor. His actions were not a fair or legitimate criticism but were reckless and inflammatory, especially given the media’s presence which amplified the damage. The proper recourse for his grievances was a confidential administrative complaint with the Supreme Court, not a public spectacle. By choosing the latter, he violated his duty of fidelity to the court and engaged in conduct prejudicial to the administration of justice. His suspension underscores that a lawyer’s right to free speech is tempered by the higher duty to avoid irresponsible attacks on judicial officers.