REGALA V. SANDIGANBAYAN 262 SCRA 124 (1996) G.R. No.

105938 September 20, 1996

ISSUE: whether or not the lawyers fiduciary duty may be asserted in refusing to disclose the identity of
clients

GENERAL RULE: a lawyer may NOT invoke the privilege and refuse to divulge the name or identity of his
client.

EXCEPTIONS TO THE RULE:

1. Client identity is privileged where a strong probability exists that revealing the clients name
would implicate that client in the very activity for which he sought the lawyers advice.

2. Where disclosure would open the client to civil liability, his identity is privileged.

3. Where the governments lawyers have no case against an attorneys client unless, by revealing
the clients name, the said name would furnish the only link that would form the chain of
testimony necessary to convict an individual of a crime, the clients name is privileged.

Other situations which could qualify as exceptions to the general rule:

1. Content of any client communication to a lawyer relevant to the subject matter of the legal
problem on which the client seeks legal assistance.

2. Where the nature of the attorney-client relationship has been previously disclosed and it is the
identity which is intended to be confidential, since such revelation would otherwise result in
disclosure of the entire transaction.