G.R. No. A.C. No. 13521. June 27, 2023
IN RE: ATTY. LORENZO G. GADON’S VIRAL VIDEO AGAINST RAISSA ROBLES

FACTS

The Supreme Court, acting on its own initiative pursuant to Section 27, Rule 138 of the Rules of Court, commenced an administrative case against Atty. Lorenzo G. Gadon after a video clip of him uttering profanities against journalist Raissa Robles went viral on social media. In the video, Atty. Gadon, while inside a parked car, angrily stated: “Hoy, Raissa Robles, puki ng ina mo, hindot ka. Putang ina mo. Ano’ng pinagsasabi mong hindi nagbayad si BBM ng taxes? May certification ‘yan galing sa BIR. Puking ina mo! Hindot ka! Putang ina mo, Raissa Robles! Magpakantot ka sa aso! Puking ina mo! Hindot ka! Putang ina mo!” The Court noted this was not his first offense, citing prior incidents including threatening Muslim communities, disrespecting former Chief Justice Sereno’s supporters, acts of dishonesty during impeachment proceedings, and maliciously imputing that former President Aquino died of HIV. The Court found his language violated Rule 7.03 of the Code of Professional Responsibility (CPR) and constituted prima facie gender-based online sexual harassment under Republic Act No. 11313 (Safe Spaces Act). Atty. Gadon was ordered to show cause why he should not be disbarred and was preventively suspended. In his Comment, Atty. Gadon argued the preventive suspension was without due process, claimed he was singled out due to his political connections, and moved for the inhibition of Justices Leonen and Caguioa. He asserted his outburst was provoked by Robles’ allegedly false tweets about Bongbong Marcos’ tax payments, that the video was intended only for Robles and not for public posting, and that his expletives were not gender-based but expressions of anger. He cited Reyes v. People to argue that phrases like “putang ina mo” are common expressions of displeasure.

ISSUE

Should Atty. Gadon be disbarred?

RULING

Yes, Atty. Gadon is disbarred. The Court held that he demonstrated unfitness for the legal profession due to his lack of good moral character. Although the case was initiated under the CPR, the Court applied the retroactive provisions of the new Code of Professional Responsibility and Accountability (CPRA), which took effect on May 30, 2023. The Court rejected Atty. Gadon’s arguments: (1) The preventive suspension was valid as an exercise of the Court’s inherent power to protect the public and the integrity of the profession; (2) The motions for inhibition of Justices Leonen and Caguioa were denied, as no evidence of bias was shown, and their prior rulings on related matters did not constitute prejudgment; (3) Atty. Gadon’s claim of being provoked by Robles’ tweets did not justify his vitriolic language, which was not protected speech but constituted gender-based sexual harassment under R.A. 11313, as the expletives targeted Robles’ gender and were publicly disseminated; (4) His prior misconduct, including disrespect toward the Court and other individuals, demonstrated a pattern of behavior inconsistent with the standards of the legal profession. The Court emphasized that lawyers must uphold dignity, respect, and gender sensitivity. Considering the gravity of his actions and his repeated offenses, disbarment was deemed appropriate to preserve the integrity of the bar. Atty. Gadon’s name was ordered stricken from the Roll of Attorneys, effective immediately.