**Facts:**
* **Initial Dispute:** Danilo Cris, an employee, filed a labor case against Erectors Inc. for alleged unfair termination. The Philippine Overseas Employment Administration (POEA) ruled in favor of Cris.
* **Petitioner’s Action:** Erectors Inc. filed a motion for reconsideration or appeal against the POEA decision, contending that their motion was filed within ten working days according to the 1984 POEA Rules and Procedures, specifically citing Rule XXIV, Sec. 1, and Rule XXV, Sec. 2.
* **Denial by POEA:** The POEA denied Erectors Inc.’s motion, maintaining that the motion was not filed within the legally mandated period.
* **Escalation to NLRC:** Erectors Inc. elevated the case to the NLRC, which upheld the POEA’s decision.
* **Certiorari Petition:** Erectors Inc. then sought a certiorari under Rule 65 before the Supreme Court, questioning the NLRC’s dismissal of their motion for reconsideration.
**Procedural History:**
* **Supreme Court’s Initial Action:** On October 5, 1987, the Supreme Court required the petitioner’s counsels to provide the source of the cited POEA rules. This was reiterated in a subsequent resolution dated December 2, 1987.
* **Petitioner’s Compliance:** Petitioner’s counsels claimed the rules could be found in the 1984 POEA Rules & Regulations and provided a non-certified xerox copy.
* **Supreme Court’s Decision; February 29, 1988:** The Court dismissed the petition and lifted the previously issued Temporary Restraining Order. The Court admonished the counsels for misleading citations with a warning of severe penalties for repetition.
* **Counsels’ Misconduct:** Despite warnings, the counsels continued citing the non-existent “ten working day rule” in their Motion for Reconsideration.
* **SC’s Final Resolution, April 25, 1988:** The Court denied the Motion for Reconsideration with finality and required the counsels to show cause for not being held in contempt.
* **Counsels’ Explanation:** In their Compliance dated May 30, 1988, the counsels asserted their actions were in the interest of defending their client but admitted the rule did not exist. The Supreme Court found this unsatisfactory.
**Issues:**
1. **Existence of the Cited Rules:** Whether the 1984 POEA Rules & Procedures indeed contained the “ten working day rule.”
2. **Counsels’ Misrepresentation and Conduct:** Whether the counsels for the petitioner, by repeatedly citing non-existent rules, engaged in deceit and professional misconduct.
**Court’s Decision:**
* **On the Existence of the Rules:** The Supreme Court confirmed after verification that the POEA rules cited by the petitioner’s counsels did not exist. The applicable rule for filing appeals within POEA was ten calendar days, not ten working days.
* **On Counsels’ Misrepresentation:**
– **Misconduct:** The Court found that the counsels repeatedly and knowingly cited non-existent rules to mislead the Court, undermining the judicial process.
– **Sanction:** The Court suspended Attys. Prescillano F. Adamos and Julian F. Barrameda from the practice of law for six months effective immediately for their misconduct, reaffirming their duty to uphold justice and not mislead the Court.
**Doctrine:**
– **Attorney’s Ethical Duty:** Lawyers must not engage in deceit, fraud, or misrepresentation. Their primary duty is to the administration of justice, over and above their obligation to their clients.
– **Professional Misconduct:** Willful misrepresentation or citing non-existent laws or procedural rules constitutes professional misconduct that can lead to suspension or removal from the practice of law.
**Class Notes:**
– **Elements of Procedural Misconduct:**
– Filing under fabricated or non-existent rules.
– Repeated insistence on such rules after judicial warnings.
– Evidence of intent to mislead the Court.
– Legal provisions involved: Attorney’s Oath, Sec. 27, Rule 138 (Rules of Court).
– **Key Statutory Provisions:**
– **Attorney’s Oath (Form 28, Appendix of Forms, Rules of Court):** A solemn promise to do no falsehood and not to mislead the court.
– **Sec. 27, Rule 138:** Grounds for suspension/removal of attorneys like deceit, malpractice, violation of oath, or disobedience of a lawful court order.
**Historical Background:**
This case highlights the imperative of ethical practice within the legal profession in the Philippines during the mid-1980s. The Court’s firm stance against deceitful practices by members of the bar underscores the critical role of integrity in the judicial process. The judiciary’s commitment to upholding ethical standards amongst practitioners serves as a deterrent against misconduct and reinforces public confidence in the legal system.
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