The Supreme Court has affirmed the importance of maintaining the integrity of the judicial system by holding an attorney accountable for attempting to influence a judge and engaging in unethical behavior. The Court emphasized that lawyers must refrain from any actions that could be perceived as influencing court decisions, and those who violate these principles face severe consequences, including suspension or disbarment. This case serves as a stern reminder of the ethical obligations that all lawyers must uphold to preserve public trust in the legal profession.

When Justice is Negotiable: Can Lawyers Exploit Connections and Bribe Court Officers?

This case revolves around a complaint filed by Judge Ariel Florentino R. Dumlao, Jr. against Atty. Manuel N. Camacho for alleged violations of the Code of Professional Responsibility. The accusations include bribery, attempts to influence the complainant, and disrespect toward court officers. The central question is whether Atty. Camacho’s actions, including name-dropping, offering a share of attorney’s fees, and threatening court personnel, constitute professional misconduct that warrants disciplinary action.

The case began with CV Case No. 2004-0181-D, entitled “Pathways Trading International, Inc. (Pathways) versus Univet Agricultural Products, Inc., et al. (defendants),” pending before the Regional Trial Court (RTC) of Dagupan City, Pangasinan, Branch 42, where Judge Dumlao presided. Atty. Camacho represented Pathways in this case. Judge Dumlao alleged that Atty. Camacho attempted to fraternize with him, mentioning his closeness to important figures, including Justices of the Supreme Court, and highlighting his connections with the University of the Philippines (UP) College of Law.

As the case progressed, Pathways filed a motion for summary judgment, which the RTC granted on January 30, 2014, finding no genuine issue in the case. The defendants, through new counsel, Atty. Geraldine U. Baniqued, filed a notice of appeal. According to Judge Dumlao, Atty. Camacho then began calling him, promising a share of his attorney’s fees in exchange for denying the notice of appeal and issuing a writ of execution. This offer was accompanied by a threat to file a disbarment case against Judge Dumlao, insinuating that his connections would ensure the judge’s disbarment.

The situation escalated on March 6, 2014, when Pathways, through Atty. Camacho, filed a Motion to Deny Appeal with a motion for the issuance of execution. The RTC denied the defendants’ notice of appeal on April 1, 2014, citing that Atty. Baniqued was not properly substituted as counsel. On April 28, 2014, the RTC issued a Certificate of Finality and a Writ of Execution. On the same day, Atty. Camacho and representatives from Pathways allegedly pressured Court Sheriff Russel Blair Nabua to serve the writ of execution at the defendants’ office in Mandaluyong City.

Judge Dumlao reported that on May 22, 2014, Atty. Camacho barged into his chambers, demanding that he order Sheriff Nabua to sign a Garnishment Order that Atty. Camacho himself had prepared. The order sought the release of a supposed garnished check of one of the defendants, addressed to Rizal Commercial Bank Corporation (RCBC), amounting to P18,690,000,643.00, in favor of Pathways. Judge Dumlao refused and told Atty. Camacho to speak with Sheriff Nabua. Sheriff Nabua also refused to sign the document, citing that the defendants had offered personal property to satisfy the writ of execution, which required holding the garnishment in abeyance.

Atty. Camacho then allegedly made threatening statements to Sheriff Nabua, such as, “Kapag hindi mo pipirmahan ito, papatanggal kita”, “Alam ng nasa itaas ito.”, “Alam ng dalawang Justices ito.” (If you don’t sign this, I’ll have you removed,” “Those above know about this,” “Two Justices know about this.”). He also sent several text messages to Judge Dumlao, accusing him and Sheriff Nabua of graft and threatening to file pleadings with the Supreme Court. Following these events, Judge Dumlao filed an Incident Report with the Office of the Court Administrator (OCA), leading to the disbarment complaint against Atty. Camacho.

The Supreme Court emphasized that lawyers must adhere to the ethical standards of the legal profession as outlined in the Code of Professional Responsibility. According to the Court in Belleza v. Atty. Macasa, “Public confidence in law and in lawyers may be eroded by the irresponsible and improper conduct of a member of the bar. Thus, every lawyer should act and comport himself in a manner that would promote public confidence in the integrity of the legal profession.”

The Court found Atty. Camacho guilty of violating the Code and the Lawyer’s Oath through influence peddling, attempted bribery, threatening court officers, and disrespecting court processes. By implying that he could influence Supreme Court Justices, Atty. Camacho undermined the integrity of the judicial system. His actions violated Canon 13, Rule 13.01, Canon 10, and Canon 10.01 of the Code of Professional Responsibility, which collectively prohibit lawyers from attempting to influence the court, engaging in falsehoods, and failing to act with candor and fairness.

Canon 13 of the Code of Professional Responsibility explicitly states:

A LAWYER SHALL RELY UPON THE MERITS OF HIS CAUSE AND REFRAIN FROM ANY IMPROPRIETY WHICH TENDS TO INFLUENCE, OR GIVES THE APPEARANCE OF INFLUENCING THE COURT.

Rule 13.01 further clarifies:

A lawyer shall not extend extraordinary attention or hospitality to, nor seek opportunity for cultivating familiarity with Judges.

In addition to influence peddling, Atty. Camacho’s promise to share attorney’s fees with Judge Dumlao in exchange for a favorable ruling constituted attempted bribery. The Court pointed out that such actions violate Canon 10 and Rule 10.01 of the Code, which mandate candor, fairness, and good faith toward the court. His conduct also violated Canon 11 and Canon 11.03, which require lawyers to maintain respect for the courts and abstain from scandalous or offensive behavior.

The Court referenced several prior cases to determine the appropriate penalty. In Plumptre v. Atty. Rivera, a lawyer was suspended for three years for soliciting money to bribe a judge. Similarly, in Rau Sheng Mao v. Atty. Velasco, a lawyer was suspended for two years for bragging about his influence over judges. Considering these precedents, the IBP recommended a penalty of suspension from the practice of law for six months, which the Court modified to two years, noting the gravity and seriousness of Atty. Camacho’s offenses.

Although Atty. Camacho had already been disbarred in a previous case, Sison, Jr. v. Atty. Camacho, the Court deemed it necessary to impose the corresponding penalty of suspension for two years. This penalty would be recorded in his personal file in the Office of the Bar Confidant (OBC). The Court reasoned that while there is no double disbarment, recording the additional infractions would provide a comprehensive record of his misconduct, which would be considered should he ever apply for the lifting of his disbarment.

FAQs

What was the key issue in this case?	The key issue was whether Atty. Manuel N. Camacho committed professional misconduct by attempting to influence a judge, offering a bribe, threatening court officers, and disrespecting court processes. The Supreme Court assessed whether his actions violated the Code of Professional Responsibility and warranted disciplinary action.
What specific actions did Atty. Camacho take that led to the complaint?	Atty. Camacho allegedly fraternized with the judge, mentioned his connections to Supreme Court Justices, offered a share of his attorney’s fees in exchange for a favorable ruling, threatened to file a disbarment case, and pressured a court sheriff to sign a garnishment order. These actions were reported by Judge Dumlao and formed the basis of the disbarment complaint.
What are the relevant provisions of the Code of Professional Responsibility that Atty. Camacho violated?	Atty. Camacho violated Canons 10, 11, 13, and 19, as well as Rules 10.01, 11.03, 13.01, and 19.01 of the Code of Professional Responsibility. These provisions pertain to maintaining candor and fairness to the court, respecting judicial officers, refraining from impropriety, and representing clients with zeal within the bounds of the law.
What was the IBP’s recommendation in this case?	The IBP Commission on Bar Discipline initially recommended disbarment, but the IBP Board of Governors reduced the recommendation to a six-month suspension from the practice of law. The Supreme Court ultimately modified the penalty to a two-year suspension.
Why did the Supreme Court impose a penalty when Atty. Camacho had already been disbarred?	The Supreme Court imposed the penalty of suspension for two years for recording purposes in Atty. Camacho’s personal file in the Office of the Bar Confidant (OBC). This ensures that his record accurately reflects all instances of misconduct, which may be considered if he ever applies for the lifting of his disbarment.
What is the significance of influence peddling in the context of legal ethics?	Influence peddling undermines the integrity of the judicial system by suggesting that outcomes can be determined by personal connections rather than the merits of the case. It erodes public trust and violates the ethical obligations of lawyers to uphold the dignity and fairness of the legal process.
How does this case relate to the Lawyer’s Oath?	Atty. Camacho’s actions violated the Lawyer’s Oath, which requires attorneys to obey the laws and legal orders of duly constituted authorities, to abstain from falsehoods, and to conduct themselves with fidelity to both the courts and their clients. His attempts to bribe and threaten court officers directly contradict these obligations.
What can other lawyers learn from this case?	Lawyers can learn that maintaining ethical conduct, respecting the judicial process, and avoiding any appearance of impropriety are paramount. The case underscores the importance of upholding the integrity of the legal profession and the severe consequences that can result from attempting to influence court decisions through unethical means.

This decision reaffirms the judiciary’s commitment to upholding the highest standards of ethical conduct within the legal profession. It serves as a crucial precedent, reminding attorneys of their duty to act with integrity and respect for the judicial system. The Supreme Court’s firm stance against influence peddling and bribery sends a clear message that such misconduct will not be tolerated and will be met with appropriate disciplinary measures.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: JUDGE ARIEL FLORENTINO R. DUMLAO, JR. VS. ATTY. MANUEL N. CAMACHO, A.C. No. 10498, September 04, 2018