G.R. No. A.C. No. 6973 ; February 13, 2006
Robert Francis F. Maronilla and Rommel F. Maronilla, Represented by Atty. Ramon M. Maronilla, Complainants, vs. Attys. Efren N. Jorda and Ida May J. La’o, Respondents.

FACTS

This administrative case arose from a fraternity-related assault on student Ferdinand Ocampo within the University of the Philippines (UP) Diliman campus. The UP Diliman Legal Office, through Atty. Efren N. Jorda, filed a formal charge before the Student Disciplinary Tribunal (SDT) against several students, including the complainant Maronilla brothers. After proceedings, the SDT, in a Decision dated May 31, 2004, dismissed the complaint against the Maronilla brothers for lack of substantial evidence, while finding five other students guilty and recommending their expulsion. The SDT noted Ocampo’s difficulty in positively identifying the twins, Robert Francis and Rommel.
Dissatisfied, Atty. Jorda, as University Legal Counsel, filed a Motion for Partial Reconsideration and later an Extended Manifestation before the UP Office of the President, seeking to hold the Maronilla brothers equally liable. Atty. Ida May J. La’o, as Chief Legal Officer, noted the Extended Manifestation. The father of the Maronilla brothers, Atty. Ramon Maronilla, then filed a complaint with the Integrated Bar of the Philippines (IBP) against respondents Jorda and La’o for violating the Code of Professional Responsibility.

ISSUE

Whether respondents Atty. Efren N. Jorda and Atty. Ida May J. La’o committed professional misconduct by filing an appeal or motion for reconsideration from a Student Disciplinary Tribunal decision.

RULING

The Supreme Court approved the IBP’s findings, dismissing the complaint against Atty. La’o but reprimanding Atty. Jorda for gross ignorance of the law and for violating Rule 12.04 of the Code of Professional Responsibility, which prohibits a lawyer from misusing court processes.
The legal logic is clear: the applicable UP rules of student discipline at the time did not provide for an appeal or a motion for reconsideration from a decision of the SDT. The process was final at the SDT level, with its decision being recommendatory to the UP President. By initiating a Motion for Partial Reconsideration and an Extended Manifestation before the Office of the President, Atty. Jorda invoked a non-existent remedy. This constituted a misuse of legal process, as it unduly delayed the finality of the SDT’s exoneration of the complainants and attempted to subvert the established procedure. His actions demonstrated a lack of familiarity with the governing rules he was duty-bound to uphold as a university legal officer.
The Court distinguished Atty. La’o’s liability, as her act of merely “noting” the Extended Manifestation did not constitute active participation in filing the improper pleading. The Court emphasized that a lawyer must be circumspect and act within the boundaries of prescribed procedures. Atty. Jorda’s failure to do so warranted the disciplinary penalty of reprimand.