AC 8208; (January, 2018) (Digest)
A.C. No. 8208. January 10, 2018. RET. JUDGE VIRGILIO ALPAJORA, Complainant, v. ATTY. RONALDO ANTONIO V. CALAYAN, Respondent.
FACTS:
This administrative case originated from a counter-complaint filed by Retired Judge Virgilio Alpajora against Atty. Ronaldo Antonio V. Calayan. The counter-complaint arose after Atty. Calayan filed an administrative case against Judge Alpajora for alleged ignorance of the law, which the Court dismissed as the issues raised were judicial in nature. Judge Alpajora’s counter-charges stemmed from an intra-corporate controversy (Civil Case No. 2007-10) involving the Calayan Educational Foundation Inc. (CEFI), where Atty. Calayan was a party and represented himself as “Special Counsel pro se.”
Judge Alpajora alleged that after he issued an Omnibus Order in the intra-corporate case, Atty. Calayan filed the administrative complaint against him. He further accused Atty. Calayan of a pattern of abusive litigation conduct. This included filing multiple civil and criminal cases against opposing parties and their lawyers, initiating several administrative complaints against different judges who handled the CEFI case (leading to successive inhibitions), and submitting numerous repetitive and prohibited pleadings. Complainant asserted these actions were designed to harass opponents, delay proceedings, and prevent the court from effectively resolving the corporate dispute.
ISSUE
Whether Atty. Ronaldo Antonio V. Calayan violated the Code of Professional Responsibility and should be disciplined.
RULING
Yes, the Supreme Court suspended Atty. Calayan from the practice of law for one year. The Court found that his conduct demonstrated a clear abuse of the legal processes and a violation of his duties as a lawyer. The legal logic centers on the principle that while a lawyer has the duty to defend a client’s rights with zeal, this must be done within the bounds of law and propriety. A lawyer is an officer of the court and must not misuse judicial mechanisms to harass opponents, unduly delay proceedings, or obstruct the administration of justice.
Atty. Calayan’s actions—filing multiple cases arising from the same cause, initiating baseless administrative complaints against judges solely due to unfavorable orders, and submitting repetitive pleadings—constituted a blatant misuse of court processes. This behavior violated specific rules under the Code of Professional Responsibility, including Rule 12.02 (prohibiting filing multiple actions from the same cause), Rule 12.04 (prohibiting unduly delaying a case or misusing court processes), and Rule 11.04 (prohibiting attributing to a judge motives not supported by the record). His conduct transcended aggressive advocacy and became obstructive, undermining the integrity of the judicial system and wasting its resources. The one-year suspension serves as a disciplinary measure to correct such misconduct and to deter similar abuses by other members of the bar.