Surigao Mineral Reservation Board vs Gaudencio Cloribel

Facts: In 1968, the Supreme Court promulgated a unanimous decision (24 SCRA 491; G.R. No. L-27072)
which was not favorable to MacArthur International Minerals Co. The latter’s lawyer, Atty. Vicente Santiago
then filed a motion for reconsideration. Eventually, a third motion for reconsideration was submitted by him
where the following paragraph was stated:

6. Unfortunately for our people, it seems that many of our judicial authorities believe that they are the chosen
messengers of God in all matters that come before them, and that no matter what the circumstances are,
their judgment is truly ordained by the Almighty unto eternity. Some seem to be constitutionally incapable
of considering that any emanation from their mind or pen could be the product of unjudicial prejudice or
unjudicial sympathy or favoritism for a party or an issue. Witness the recent absurdity of Judge Alikpala
daring to proceed to judge a motion to hold himself in contempt of court — seemingly totally oblivious or
uncomprehending of the violation of moral principle involved — and also of Judge Geraldez who refuses to
inhibit himself in judging a criminal case against an accused who is also his correspondent in two other
cases. What is the explanation for such mentality? Is it outright dishonesty? Lack of intelligence? Serious
deficiency in moral comprehension? Or is it that many of our government officials are just amoral?

Scattered in his motion were other statements where he attacked the 1968 decision of the Supreme Court
as false, erroneous, and illegal.
In another motion, Atty. Santiago sought the inhibition of two Justices: Justice Fred Castro, because
allegedly, he is the brother of the vice president of the opposing party. And Chief Justice Roberto
Concepcion because immediately after the 1968 decision, his son was appointed to a significant position
in the government. (Here Atty. Santiago implied that the justices were not fair and that their decision was
influenced).
In his defense, Atty. Santiago said that he originally deleted the above paragraph and was only included
due to inadvertence. But that any rate, he averred that the language he used was necessary to defend his
client.
ISSUE: Whether or not Atty. Vicente Santiago is guilty of contempt.
HELD: Yes. Lawyers are administrators of justice, oath-bound servants of society, their first duty is not to
their clients, as many suppose, but to the administration of justice; to this, their clients’ success is wholly
subordinate; and their conduct ought to and must be scrupulously observant of law and ethics. Thus,
Santiago’s defense is not tenable.
A lawyer must avoid language that tend to create an atmosphere of distrust, of disbelief in the judicial
system. A lawyer’s duties to the Court have become common place. Really, there could hardly be any valid
excuse for lapses in the observance thereof.
Section 20(b), Rule 138 of the Rules of Court, in categorical terms, spells out one such duty: ‘To observe
and maintain the respect due to the courts of justice and judicial officers.’
It is the duty of the lawyer to maintain towards the Courts a respectful attitude, not for the sake of the
temporary incumbent of the judicial office, but for the maintenance of its supreme importance.
Atty. Santiago was fined for his infractions.

Violations: Canon 11 – “Alawyer shall observe and maintain the respect due to the courts and to judicial
officers and should insist on similar conduct by others.”

Rule 11.03 – “A lawyer shall abstain from scandalous, offensive or menacing language or behavior before
the Courts.”
Rule 11.04 – “A lawyer shall not attribute to a Judge motives not supported by the record or have no
materiality to the case.”