**Facts:**
1. On July 26, 2004, Corazon E. Recio filed a complaint for illegal dismissal against Amalgamated Motors Philippines, Inc. (AMPI) before the Labor Arbiter (LA), where Atty. Ulpiano S. Madamba and Atty. Manolito M. Apostol Jr. were counsel for AMPI.
2. On February 23, 2006, the LA dismissed the complaint, finding no constructive dismissal in Recio’s transfer from Quezon City to San Fernando, Pampanga, stating it was in good faith for corporate needs.
3. Aggrieved, Recio appealed to the National Labor Relations Commission (NLRC), which reversed the LA’s decision on March 25, 2009, ruling that Recio was constructively dismissed due to her demotion and reassignment done as retaliation for union activities.
4. The NLRC awarded backwages and separation pay to Recio totaling Php 767,542.82. Respondents’ motion for reconsideration was denied on July 31, 2009.
5. Respondents filed a Petition for Certiorari under Rule 65 with the Court of Appeals (CA), docketed as CA-G.R. SP No. 110950, objecting to the NLRC ruling. The NLRC declared its Decision final on October 17, 2009, as no restraining order was issued by the CA.
6. On January 4, 2010, Recio moved for the execution of the NLRC Decision, which was granted on February 1, 2010. Respondents opposed and escalated the matter but were denied by the NLRC.
7. Simultaneously, respondents filed a complaint for damages against Recio in the Regional Trial Court, deemed as a maneuver to delay execution.
8. Proceedings in CA affirmed the NLRC ruling on July 9, 2010. Respondents’ subsequent motion for reconsideration was denied on October 1, 2010.
9. On November 24, 2010, the Supreme Court denied the petition under G.R. No. 194035, reinforcing the NLRC’s decisions. Respondents’ motion for reconsideration was denied on March 7, 2011.
10. Despite final judgments, respondents continued to challenge the execution, leading Recio to file a disbarment complaint before the Integrated Bar of the Philippines (IBP) against them for abuse of court processes.
**Issues:**
1. Whether the respondents should be held administratively liable for deliberately delaying the execution of a final judgment by employing frivolous legal maneuvers.
2. The propriety and adequacy of the recommended penalty for the respondents’ actions in light of their professional duties and legal ethics.
**Court’s Decision:**
1. **Administrative Liability:** The Philippine Supreme Court concurred with the IBP’s findings that respondents abused court processes to delay the execution of final NLRC rulings, violating several ethical norms including the Lawyer’s Oath and the Code of Professional Responsibility.
2. **Penalty:** While the IBP recommended a six-month suspension, the court expanded this to a one-year suspension from the practice of law considering the respondents’ persistent and dilatory tactics, lack of remorse, and the significant detriment suffered by complainant Recio.
**Doctrine:**
– **Speedy Administration of Justice:** The ruling reiterates that lawyers have a primary duty to expedite the resolution of disputes. Any behavior that unduly delays court processes is a breach of professional ethics.
– **Final Judgment Execution:** Final and executory judgments must be respected, and attorneys should not misuse procedural remedies to subvert justice or delay entitlements legally granted by courts.
**Class Notes:**
– **Ethical Obligations of Lawyers:**
– **Rule 1.03:** No lawyer shall delay any man’s cause for money or malice.
– **Rule 10.03:** Lawyers must not misuse procedural rules to defeat justice.
– **Rules 12.02 & 12.04:** Restrictions against filing multiple suits arising from the same cause and undue case delay, especially post-judgment.
– **Canon 1:** Obedience to laws and promotion of respect for legal processes.
**Historical Background:**
This case fits within the broader context of efforts to reinforce the integrity of the Philippine judicial system by holding legal practitioners accountable for unethical behavior. It reflects ongoing jurisprudential themes seeking to deter manipulations of the legal system to ensure fair and speedy administration of justice.
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