Adm. Case No. 1769. June 08, 1992 (Case Brief / Digest)

### Title:
**Lantoria v. Bunyi: Discipline and Ethical Conduct in Legal Profession**

### Facts:
Cesar L. Lantoria filed an administrative complaint against Atty. Irineo L. Bunyi, accusing him of “graft and corruption, dishonesty and conduct unbecoming of a member of the Integrated Bar of the Philippines, and corruption of the judge and bribery.” These allegations stemmed from Bunyi’s involvement in Civil Case Nos. 81, 83, and 88 before the Municipal Court of Esperanza, Agusan del Sur. Bunyi was representing Mrs. Constancia Mascarinas, seeking to eject squatters from her farm, a case presided over by Municipal Judge Vicente Galicia. Defendants were declared in default, and Bunyi was alleged to have prepared the decision drafts for these cases, which was seen as an unethical attempt to influence the court proceedings.

The case traveled through a procedural landscape from the Supreme Court’s referral to the Solicitor General for investigation, resulting in a recommendation for disciplinary action. This procedural journey was marked by a series of hearings, respondent Bunyi’s admissions, and eventual recommendation by the Solicitor General for a one-year suspension from law practice.

### Issues:
1. Whether Atty. Irineo L. Bunyi’s acts of preparing decision drafts for Civil Case Nos. 81, 83, and 88 amount to unethical conduct and attempt to influence the court.
2. The impact of the complainant’s withdrawal of the complaint on the case’s merits.

### Court’s Decision:
The Philippine Supreme Court found Atty. Irineo L. Bunyi guilty of unethical practice for attempting to influence the court proceedings of Civil Case Nos. 81, 83, and 88. Despite the complainant’s withdrawal, the court emphasized the importance of proceeding with the determination of the case’s merits, as Bunyi himself admitted the existence of the letters that served as the basis for the complaint. The Court suspended Atty. Bunyi from the practice of law for one year, underlining the violation of Canon No. 3 of the Canons of Professional Ethics and similar provisions in the new Code of Professional Responsibility.

### Doctrine:
This case reiterates the doctrine that lawyers must refrain from any impropriety that tends to influence or gives the appearance of influencing the court, as enshrined in Canon 13 of the Code of Professional Responsibility and Canon No. 3 of the Canons of Professional Ethics.

### Class Notes:
– The essential principle in this case is the ethical boundary that legal professionals must not cross in terms of influencing court decisions. The pertinent rules include Canon No. 3 of the Canons of Professional Ethics and Canon 13 of the Code of Professional Responsibility.
– The case underscores the judiciary’s independence and the critical role of lawyers in upholding ethical standards in legal practice.

### Historical Background:
This case reflects the legal community’s ongoing concerns about ethical conduct and the mechanisms in place to discipline members of the Bar who violate professional standards. It underscores the judiciary’s efforts to maintain the integrity of legal practice in the Philippines, illustrating the balance between addressing complaints and ensuring that lawyers adhere to ethical guidelines critical for the legal profession’s credibility and the justice system’s effectiveness.


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