A.C. No. 10498. September 04, 2018
JUDGE ARIEL FLORENTINO R. DUMLAO, JR., COMPLAINANT, VS. ATTY. MANUEL N. CAMACHO, RESPONDENT.

FACTS

Complainant Judge Ariel Florentino R. Dumlao, Jr., presided over a civil case where respondent Atty. Manuel N. Camacho was counsel for the plaintiff. Complainant alleged that during the pendency of the case, respondent attempted to fraternize with him, name-dropping Supreme Court Justices and claiming close friendships with them, including then Chief Justice Sereno and Justice Leonen. After the court granted respondent’s motion for summary judgment and the defendants filed a notice of appeal, respondent escalated his conduct. He called the complainant, offering to share a portion of his attorney’s fees in exchange for the denial of the notice of appeal and the issuance of a writ of execution. He accompanied this bribery attempt with a threat to file a disbarment case against the judge, insinuating his connections would ensure the complaint’s success.
Subsequently, after the court issued a writ of execution, respondent barged into the judge’s chambers demanding he order the sheriff to sign a garnishment order respondent himself had prepared. When the judge dismissed him, respondent confronted the court sheriff, Sheriff Russel Blair Nabua, demanding he sign the document. Upon the sheriff’s justified refusal—citing procedural rules as the judgment debtors had offered personal property for settlement—respondent threatened the sheriff’s removal, stating, “Kapag hindi mo pipirmahan ito, papatanggal kita,” and again invoking his knowledge of “two Justices.”

ISSUE

Whether respondent Atty. Manuel N. Camacho violated the Code of Professional Responsibility and the Lawyer’s Oath through his actions of bribery, attempted influence peddling, and disrespect toward court officers.

RULING

Yes, the Supreme Court found respondent guilty of multiple violations of the Code of Professional Responsibility and suspended him from the practice of law for two years. The legal logic is grounded in the fundamental duties of a lawyer to uphold the integrity of the legal profession and the administration of justice. A lawyer is an officer of the court and must avoid any conduct that undermines public confidence in the judiciary. Respondent’s act of offering a bribe to a judge constitutes a direct assault on judicial independence and corrupts the duty of a lawyer to act with candor and fairness (Rule 10.01, Canon 10). His attempt to use perceived personal connections with Supreme Court Justices to influence the judge and threaten the sheriff constitutes gross misconduct and a flagrant violation of the prohibition against using improper means to achieve a legal objective (Canon 11, Rule 11.03).
Furthermore, his disrespectful and threatening behavior toward the sheriff, a court officer, demonstrated a failure to observe respect for the law and legal processes (Canon 19, Rule 19.01). The Court emphasized that a lawyer’s duty to his client is bounded by the rule of law; it does not justify browbeating court personnel or attempting to subvert established judicial procedures. The totality of respondent’s actions—fraternization, bribery, influence peddling, and intimidation—revealed a pattern of conduct unbecoming of a lawyer, necessitating disciplinary action to protect the public and the legal system. However, the Court noted that respondent had already been disbarred in a separate case (Sison, Jr. v. Camacho). Therefore, while the two-year suspension was the proper penalty, it could no longer be imposed. The Court ordered that this penalty be recorded and considered should respondent ever apply for the lifting of his disbarment in the prior case.