TL;DR

In a disciplinary case, the Supreme Court suspended two lawyers, Atty. Luis K. Lokin, Jr. and Atty. Sikini C. Labastilla, for professional misconduct. They were found guilty of creating and being complicit in a misleading checkbook entry that insinuated bribery of the Sandiganbayan, a special court in the Philippines, to obtain a favorable ruling. This act was deemed a violation of the Code of Professional Responsibility, specifically Canons 7 and 11, which mandate lawyers to uphold the integrity of the legal profession and respect for the courts. The ruling underscores that lawyers must maintain the dignity of the judiciary and refrain from actions that undermine public trust in the justice system, even amidst adversarial proceedings. Atty. Lokin, Jr. received a three-year suspension, while Atty. Labastilla was suspended for one year.

When a Checkbook Entry Casts a Shadow on Justice: Upholding Court Dignity

This case revolves around a complaint filed by PHILCOMSAT Holdings Corporation against its former lawyers, Atty. Luis K. Lokin, Jr. and Atty. Sikini C. Labastilla. The heart of the matter lies in a checkbook entry that read “Cash for Sandiganbayan, tro, potc-philcomsat case – P2,000,000.” This entry surfaced during a Senate investigation into PHILCOMSAT’s financial dealings. The Sandiganbayan, upon learning of this entry, initiated contempt proceedings, finding the lawyers guilty of insinuating judicial corruption. Subsequently, PHILCOMSAT filed this administrative case seeking the disbarment of Attys. Lokin, Jr. and Labastilla for conduct unbecoming of officers of the court.

The Supreme Court’s decision hinged on the principle that lawyers, as officers of the court, have a paramount duty to uphold the dignity and integrity of the judiciary. The Court emphasized that disciplinary proceedings against lawyers are distinct from criminal cases and serve the public welfare by ensuring that the legal profession is composed of individuals fit to practice law. The Court cited the case of Spouses Saunders v. Pagano-Calde, which clarified that administrative cases against lawyers proceed independently of criminal cases, focusing on the lawyer’s professional conduct and the integrity of the legal profession. The Court stated:

[A]dministrative cases against lawyers belong to a class of their own. They are distinct from and they may proceed independently of criminal cases. A criminal prosecution will not constitute a prejudicial question even if the same facts and circumstances are attendant in the administrative proceedings… Disciplinary proceedings involve no private interest and afford no redress for private grievance. They are undertaken and prosecuted solely for the public welfare and for preserving courts of justice from the official ministration of persons unfit to practice law. The attorney is called to answer to the court for his conduct as an officer of the court.

The Court affirmed the Sandiganbayan’s finding that the checkbook entry was indeed contumacious, implying that the court could be bribed for a Temporary Restraining Order (TRO). The evidence showed Atty. Lokin, Jr. was directly responsible for the entry. Witness testimony from the company bookkeeper confirmed that Atty. Lokin, Jr. instructed the entry’s creation. Despite his attempts to explain the entry during the Senate investigation, the Court found his justifications unconvincing, noting his “avoidance and confession posturing.”

While the Integrated Bar of the Philippines (IBP) initially absolved Atty. Labastilla, the Supreme Court disagreed. The Court highlighted circumstantial evidence linking Atty. Labastilla to the entry. He was the counsel who applied for the TRO, admitted receiving the check proceeds (allegedly as legal fees without proper accounting), and the TRO’s issuance coincided with the check date. The Court found Atty. Labastilla’s failure to properly account for the P2,000,000.00 and the lack of documentation for legal fees as significant factors in establishing his complicity.

The Supreme Court underscored the importance of Canon 11 of the Code of Professional Responsibility, which mandates lawyers to “observe and maintain the respect due to the courts and to judicial officers.” The Court also invoked Canon 7, requiring lawyers to “uphold the integrity and dignity of the legal profession.” By creating and being complicit in the defamatory checkbook entry, the lawyers violated these canons, undermining public confidence in the judiciary. The Court reiterated that respect for the courts is fundamental to the stability of the judicial institution and the administration of justice. The Court referenced Baculi v. Battung, emphasizing that acts eroding public trust in the courts warrant disciplinary action.

Considering the gravity of the offense, the Court imposed different penalties. Atty. Lokin, Jr., as the primary actor, received a suspension of three years. Atty. Labastilla, for his complicity, was suspended for one year. Both suspensions serve as a stern warning to the legal profession about the serious consequences of actions that disrespect and undermine the integrity of the courts.

FAQs

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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: PHILCOMSAT HOLDINGS CORPORATION VS. ATTY. LUIS K. LOKIN, JR. AND ATTY. SIKINI C. LABASTILLA, A.C. No. 11139, April 19, 2016