Atty. Roderick Manzano vs Atty. Rose Breatrix Cruz-Angeles

A.C. No. 11375 – Legal Ethics – Defamatory language if not relevant to the case are not privileged 

Atty. Roderick Manzano, on behalf of a client, filed an unlawful detainer case against the client of Atty. Rose Breatrix Cruz-Angeles (Atty. Trixie Angeles). Atty. Trixie and a co-counsel drafted an Answer for their client where they alleged that Atty. Manzano’s client was an “INC patsy,” “Eduardo Manalo’s pawn,” “incorrigible liar,” and “lying through her teeth.”

As a result, Atty. Manzano filed an administrative case against Atty. Trixie for alleged violations against the Code of Professional Responsibility.

ISSUE: Whether or not Atty. Trixie Angeles should be disciplined.

HELD: Yes. Atty. Trixie Angeles is suspended for six months. As a rule, statements made during a judicial proceeding are privileged. However, if the statements are irrelevant to the issues raised in the case under litigation, then the defense of privileged communication may not be invoked. Here, the statements made by Atty. Trixie were made for the purpose of insulting, dishonoring, and humiliating the client of Atty. Manzano.

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