G.R. No. A.C. No. 12843, March 18, 2021
Erlinda Bildner, Complainant, vs. Atty. Sikini C. Labastilla and Atty. Alma Kristina Alobba, Respondents.

FACTS

This administrative case for disbarment arose from an intra-corporate dispute between two groups vying for control of Philippine Overseas Telecommunications Corporation (POTC) and its subsidiary Philippine Communications Satellite Corporation (PHILCOMSAT). Complainant Erlinda Bildner, part of the Africa-Bildner group, accused respondents Atty. Sikini Labastilla and Atty. Alma Kristina Alobba of professional misconduct. Atty. Labastilla, counsel for the opposing Nieto-PCGG group, filed a complaint for injunction before the Sandiganbayan (SB) on September 21, 2005, which contained allegations that Bildner claimed were false: that Bildner’s group were not the true board members, that a representative (Locsin) was authorized to file the SB complaint despite an existing Court of Appeals (CA) Temporary Restraining Order (TRO) and Writ of Preliminary Injunction (WPI) enjoining the Nieto-PCGG group from acting as corporate officers, and that the government owned 40% of POTC. This SB complaint led to the issuance of an SB TRO on September 23, 2005, enjoining the Africa-Bildner group from acting as the board. Atty. Alobba, as Assistant Corporate Secretary of both corporations, was accused of violating the CA TRO and WPI by issuing Secretary’s Certificates on September 15, 2005, certifying the authority of Nieto-PCGG group members to represent the corporations.

ISSUE

Whether respondents Atty. Sikini Labastilla and Atty. Alma Kristina Alobba violated the Code of Professional Responsibility and should be disciplined.

RULING

The Supreme Court dismissed the complaint against Atty. Alma Kristina Alobba but found Atty. Sikini Labastilla guilty of violating Canons 1, 10, 12, and 19 of the Code of Professional Responsibility. The Court held that complainant failed to present substantial evidence proving Atty. Alobba willfully defied the CA TRO and WPI, noting she performed a ministerial duty as Assistant Corporate Secretary and that her good faith was supported by the CA’s prior denial of a contempt motion against her. However, Atty. Labastilla was suspended for three months for failing to inform the Sandiganbayan that his clients (the Nieto-PCGG group) were enjoined by the CA TRO and WPI from acting as corporate officers, an omission that allowed his clients to secure an SB TRO. The Court emphasized that lawyers must uphold court integrity and respect judicial processes, and Atty. Labastilla’s actions demonstrated a disregard for this duty. He was sternly warned that repetition would be dealt with more severely.