People of the Philippines vs Atty. Raul Sesbreno

written by Howard

G.R. No. L-62449 – 130 SCRA 465 – Legal Ethics – Libelous Conduct – Duty of Lawyers to Fellow Lawyers 

Criminal Law – Book II – Crimes Against Honor – Libel – Court pleadings are exempt from libel; Privileged Communication
Atty. Raul Sesbreno and Atty. Ramon Ceniza were opposing counsels in a civil case. At one point, Atty. Ceniza asked for a transfer of hearing. It was granted but Sesbreno and his client still appeared on the supposed trial date because they denied that they ever received notice of the postponement. Sesbreno then filed a motion to have Ceniza reimburse them the expenses they made that day. Ceniza opposed said motion and he showed evidence that Sebreno in fact received the notice of the postponement of the hearing. The trial court then directed Sesbreno to show cause why he should not be subject to contempt. In the subsequent pleadings, Ceniza accused Sesbreno of misrepresentation, prevarication, and “telling a barefaced and documented lie.” Sesbreno then filed a Reply where he accused Ceniza of being an irresponsible person, cannot be trusted, like Judas, a liar and irresponsible childish prankster. Ceniza then filed a libel case against Sesbreno.

ISSUE: Whether or not the libel case should prosper.

HELD: No. Pleadings filed in court are covered by privileged communication. They are privileged insofar as they are relevant to the cause in hand or subject of inquiry. HOWEVER, both lawyers are advised by the Supreme Court to refrain from using language unbecoming of a member of the Bar and to extend courtesy and respect to their brothers in the profession. They were warned that a repetition of same infraction will be dealt with severely. In keeping with the dignity of the legal profession, a lawyer’s language should be dignified. Choice of language is a very important requirement in the preparation of pleadings. Appropriately, in the assertion of their client’s rights, lawyers – even those gifted with superior intellect – are enjoined to rein up their tempers. Greater care and circumspection must be exercised in the preparation of their pleadings and to refrain from using abrasive and offensive language.

Read full text