G.R. No. 71169, 74376, 76394, 78182, 82281. August 30, 1989.
JOSE D. SANGALANG and LUTGARDA D. SANGALANG, et al., petitioners, vs. INTERMEDIATE APPELLATE COURT and AYALA CORPORATION, respondents.

FACTS

This consolidated Resolution addresses a contempt charge against Atty. J. Cezar Sangco, counsel for petitioners Spouses Sangalang. The Supreme Court, in a prior Resolution dated February 2, 1989, required Atty. Sangco to show cause why he should not be punished for contempt for using intemperate and accusatory language in a motion for reconsideration. In that motion, Atty. Sangco made several disparaging remarks about the Court’s Decision in the main case, which involved property rights in Bel-Air Village. He suggested the Decision read “more like a Brief for Ayala,” put the Court’s integrity and competence in “serious question,” jeopardized its campaign against graft, and manifested “unusual partiality” and “judicial arrogance.”
Atty. Sangco filed his explanation on March 2, 1989, asserting his comments were meant to challenge the Court’s reasoning and not to accuse it. He claimed he was merely defending his clients’ interests and, as a former judge, was accustomed to criticisms of judicial decisions.

ISSUE

Whether Atty. J. Cezar Sangco’s language in his motion for reconsideration constitutes contempt of court and/or professional misconduct.

RULING

Yes, Atty. Sangco is guilty of both contempt and professional misconduct. The Court found his explanations unsatisfactory. His statements were disparaging, intemperate, and an unfounded assault on the Court’s honor and integrity. The legal logic is clear: while a lawyer must zealously advocate for a client, this duty is subordinate to the higher duty to the administration of justice. A lawyer’s conduct must always be scrupulously observant of law and ethics. Earnest advocacy does not permit resort to arrogance, intimidation, innuendo, or attributing improper motives to the Court without basis.
The Court emphasized that it decided the case based solely on the records, not on outside influence. Disagreement with a trial court’s findings, which is the very purpose of an appeal, does not equate to arbitrariness. Atty. Sangco’s suggestions of partiality or corruption, unsupported by the record, transcend the bounds of fair and dignified critique. Such conduct constitutes contempt under Rule 71, Section 1 of the Rules of Court for disrespect, and violates Canon 11, particularly Rules 11.03 and 11.04, of the Code of Professional Responsibility, which prohibit scandalous or offensive language and attributing unsupported motives to a judge.
WHEREFORE, Atty. J. Cezar Sangco is SUSPENDED from the practice of law for three (3) months and ORDERED to pay a fine of P500.00.