In PO1 Jose B. Caspe v. Atty. Aquilino A. Mejica, the Supreme Court affirmed the suspension of Atty. Aquilino A. Mejica from the practice of law for two years. The Court found him guilty of violating the Code of Professional Responsibility by encouraging the filing of suits for corrupt motives and showing disrespect towards the Integrated Bar of the Philippines (IBP) proceedings. This decision underscores the importance of maintaining ethical conduct and upholding the integrity of the legal profession.

A Lawyer’s Vendetta: When Personal Grievances Cloud Professional Judgment

The case originated from a complaint filed by PO1 Jose B. Caspe against Atty. Aquilino A. Mejica for allegedly violating the Code of Professional Responsibility (CPR). Caspe claimed that Atty. Mejica disregarded conflict of interest rules by initially serving as his counsel in a case against Antonio Rodriguez, Jr., and then representing Rodriguez, Jr. when he filed a counter-affidavit. Following Caspe’s refusal to settle, Atty. Mejica allegedly threatened to file multiple cases against him until he was removed from service. Subsequently, Atty. Mejica, as counsel for Romulo Gaduena, filed a complaint for serious slander by deed against Caspe, leading Caspe to file disbarment and damages cases against Atty. Mejica.

The IBP Commission on Bar Discipline (CBD) found Atty. Mejica guilty of violating Rules 1.03, 1.04, and 10.01 of the CPR, concluding that he was corruptly motivated in encouraging the filing of suits against Caspe to fulfill his threat. The IBP Board of Governors (BOG) initially adopted the CBD’s recommendation, then modified the penalty to a three-year suspension. Atty. Mejica argued that he was not afforded due process, claiming he did not receive copies of the complaints and was unable to attend mandatory conferences.

The Supreme Court, in its resolution, emphasized that disciplinary proceedings aim to determine a lawyer’s fitness to practice law, citing that a lawyer may be disciplined for misconduct that demonstrates a lack of good moral character, honesty, and probity. The Court referenced that a clear preponderance of evidence is sufficient to establish liability in such proceedings. It reiterated that the complainant bears the burden of proving the charges against the respondent with clear, convincing, and satisfactory evidence.

“Rule 1.03. – A lawyer shall not, for any corrupt motive or interest, encourage any suit or proceeding or delay any man’s cause.”

“Rule 1.04. – A lawyer shall encourage his clients to avoid, end or settle a controversy if it will admit of a fair settlement.”

The Supreme Court agreed with the IBP CBD’s findings that Atty. Mejica’s actions were motivated by a corrupt intent to retaliate against PO1 Caspe. The Court highlighted the timing of the cases filed against Caspe, the gap between the initial incident and the filing of the slander case, and the fact that Atty. Mejica served as counsel for the criminal complainants against Caspe despite ethical proscriptions. These circumstances led the Court to conclude that Atty. Mejica violated Rules 1.03, 1.04, and 10.01 of the CPR.

Addressing Atty. Mejica’s claim of being denied due process, the Court cited Section 5, Rule V of the Rules of Procedure of the Commission on Bar Discipline Integrated Bar of the Philippines, which states that non-appearance at mandatory conferences is deemed a waiver of the right to participate in the proceedings. The Court noted that Atty. Mejica missed all four scheduled hearings, and despite claiming he did not receive copies of the complaint, records indicated that a copy was sent to him but was unclaimed. His submission of manifestations also indicated he was aware of the action against him. This showed a lack of respect for the IBP’s rules and procedures.

“SEC. 5. Non-appearance of Parties, and Non-verification of Pleadings. a) Non-appearance at the mandatory conference or at the clarificatory questioning date shall be deemed a waiver of right to participate in the proceeding. Ex parte conference or hearings shall then be conducted. Pleadings submitted or filed which are not verified shall not be given weight by the Investigating Commissioner.”

The Court emphasized that a lawyer’s refusal to obey the orders of the IBP constitutes disrespect for the judiciary and fellow lawyers. As officers of the court, lawyers are expected to comply with court directives. Atty. Mejica’s conduct was deemed unbecoming of a lawyer, as he failed to observe and maintain respect for the courts, the law, and legal processes. In line with this, the Supreme Court found Atty. Mejica in violation of Canon 11 of the CPR, which calls for lawyers to observe and give due respect to courts and judicial officers.

“Canon 11 – A lawyer shall observe and maintain the respect due to the courts and to judicial officers and should insist on similar conduct by others.”

Given that this was Atty. Mejica’s second infraction, the Court deemed it appropriate to impose a two-year suspension from the practice of law. The decision serves as a reminder to lawyers of their ethical obligations and the importance of upholding the integrity of the legal profession. The Court underscored that lawyers must not use their position to settle personal scores or disrespect legal processes.

FAQs

What was the key issue in this case?	The key issue was whether Atty. Mejica violated the Code of Professional Responsibility by encouraging the filing of suits for corrupt motives and showing disrespect towards the IBP proceedings. The Court examined his conduct in relation to ethical standards for lawyers.
What specific violations was Atty. Mejica found guilty of?	Atty. Mejica was found guilty of violating Rules 1.03, 1.04, and 10.01 of the CPR, which prohibit lawyers from encouraging suits for corrupt motives, failing to encourage settlement, and engaging in falsehoods. He also violated Canon 11 for failing to respect courts and judicial officers.
What was the basis for the IBP’s findings against Atty. Mejica?	The IBP based its findings on the circumstances surrounding the filing of cases against PO1 Caspe, including the timing, the gap between the initial incident and the filing of the slander case, and Atty. Mejica’s representation of the criminal complainants. These factors suggested a corrupt motive.
What was Atty. Mejica’s defense in the case?	Atty. Mejica argued that he was not afforded due process because he did not receive copies of the complaints and was unable to attend the mandatory conferences. He claimed he never threatened Caspe.
How did the Court address Atty. Mejica’s due process claim?	The Court rejected Atty. Mejica’s due process claim, citing the IBP rules stating that non-appearance at mandatory conferences is deemed a waiver of the right to participate. They noted that he had been notified of the proceedings but failed to claim the complaint.
What was the final penalty imposed on Atty. Mejica?	The Supreme Court suspended Atty. Mejica from the practice of law for two years, effective upon the finality of the resolution. This penalty was imposed due to the violations of the CPR and Canon 11.
Why did the Court emphasize the importance of respecting IBP directives?	The Court emphasized that a lawyer’s refusal to obey the orders of the IBP constitutes disrespect for the judiciary and fellow lawyers. As officers of the court, lawyers are expected to comply with court directives.
What does this case signify for the legal profession?	This case serves as a reminder to lawyers of their ethical obligations and the importance of upholding the integrity of the legal profession. Lawyers must not use their position to settle personal scores or disrespect legal processes, and they must adhere to the standards set forth in the CPR.

The Supreme Court’s decision in Caspe v. Mejica reinforces the critical role of ethical conduct in the legal profession. Lawyers must adhere to the highest standards of integrity and respect for legal processes to maintain the public’s trust and confidence in the justice system.

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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: PO1 Jose B. Caspe, COMPLAINANT, VS. Atty. Aquilino A. Mejica, A.C. No. 10679, March 10, 2015