G.R. No. A.C. No. 7474. September 9, 2014.
PRESIDING JUDGE JOSE L. MADRID, REGIONAL TRIAL COURT, BRANCH 51, SORSOGON CITY, Complainant, vs. ATTY. JUAN S. DEALCA, Respondent.

FACTS

Complainant Judge Jose L. Madrid filed an administrative complaint for disbarment against respondent Atty. Juan S. Dealca for gross misconduct and violation of the Code of Professional Responsibility. The complaint stemmed from Atty. Dealca’s motion to inhibit Judge Madrid and to re-raffle Criminal Case No. 2006-6795, citing “adverse incidents” between them and claiming they did not appear before each other. Judge Madrid denied the motion, characterizing it as an affront to the court’s integrity and an unethical practice, noting that Atty. Dealca had previously filed administrative and criminal cases against him which were dismissed. The Supreme Court referred the matter to the Integrated Bar of the Philippines (IBP) for investigation. The IBP-Sorsogon Chapter found that Atty. Dealca had a propensity to file administrative or criminal complaints against judges and court personnel whenever he received adverse rulings, citing five specific cases as evidence. The IBP Investigating Commissioner recommended a one-year suspension, but the IBP Board of Governors dismissed the complaint for lack of merit. Judge Madrid sought reconsideration.

ISSUE

1. Whether Atty. Dealca filed frivolous administrative and criminal complaints against judges and court personnel in violation of the Lawyer’s Oath and the Code of Professional Responsibility.
2. Whether Atty. Dealca was guilty of unethical practice in seeking the inhibition of Judge Madrid.

RULING

The Supreme Court found Atty. Dealca guilty of gross misconduct and suspended him from the practice of law for one year. The Court held that Atty. Dealca violated the Lawyer’s Oath and the Code of Professional Responsibility by engaging in the unethical practice of filing frivolous administrative and criminal complaints against judges and court personnel as a reaction to adverse rulings, instead of availing of judicial remedies. This conduct constituted harassment, undermined the integrity of the courts, and displayed a lack of respect for judicial institutions. The Court also found his motion for inhibition to be devoid of factual or legal basis, grounded purely on personal whims, and intended to embarrass the judge and delay proceedings. The Court emphasized that a lawyer’s duty is to uphold the dignity and authority of the courts, and Atty. Dealca’s actions were contrary to this duty. The Court reversed the IBP Board of Governors’ dismissal and imposed the one-year suspension.