GR L 37650; (April, 1974) (Digest)
G.R. No. L-37650 April 30, 1974
VISAYAN STEVEDORE TRANSPORTATION COMPANY (HINIGARAN BRANCH) and RAFAEL XAUDARIO, petitioners, vs. COURT OF INDUSTRIAL RELATIONS and UNITED WORKERS AND FARMERS’ ASSOCIATION (UWFA) VENANCIO DANO-OG and BUENAVENTURA AGARCIO and 137 OTHERS, respondents, ATTY. JOSE K. MANGUIAT, JR., respondent.
FACTS
This case involves a motion for reconsideration filed by Atty. Jose K. Manguiat, Jr., Chief of the Legal and Research Division of the Court of Industrial Relations (CIR). The Supreme Court had previously reprimanded Atty. Manguiat for failing to submit a required comment for the respondent CIR within an extended period granted to him. His initial submission, termed a “manifestation and comment,” was deemed unsatisfactory in both tone and substance. In his motion for reconsideration, Atty. Manguiat apologized, explained his actions were in good faith, and cited heavy workload pressures. He detailed his extensive responsibilities at the CIR and noted that only one other lawyer assisted him, who was assigned to handle Supreme Court cases but was on sick leave during the relevant period.
ISSUE
The primary issue is whether the Supreme Court should reconsider its disciplinary resolution against Atty. Manguiat for his failure to submit a proper and timely comment, considering his explanations and apology.
RULING
The Supreme Court modified its previous resolution, replacing the reprimand with an admonition for Atty. Manguiat to be more attentive to his duties. The Court upheld the principle that disciplinary action for failing to comply with court directives is standard, emphasizing that a lawyer’s duty to the Court is personal and cannot be excused by internal delegation of tasks. The Court clarified that while Atty. Manguiat could delegate work within the CIR, his ultimate accountability to the Supreme Court for timely and proper submissions remained undiminished. The Court also criticized the substantive inadequacy of his original one-paragraph comment, which merely invoked the conclusiveness of factual findings by the CIR without addressing the legal nuance established in Gonzales v. Victory Labor Union—that such conclusiveness is not absolute, especially when the lower court’s decision is closely divided on the facts.
However, the Court acknowledged Atty. Manguiat’s expression of good faith, his lack of intent to offend the Tribunal, his previously unblemished record in sixteen years at the bar, and his pledge of future carefulness. These factors, coupled with his advanced legal training (noting his LL.M. from Yale), persuaded the Court to exercise leniency. The resolution concluded by admonishing him to be more diligent in fulfilling his obligations to the courts and ordered a copy of the modified resolution to be entered into his record.