Supreme Court of the Philippines

SC suspends ex-press secretary Trixie Angeles over abusive, offensive language

Jairo Bolledo

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SC suspends ex-press secretary Trixie Angeles over abusive, offensive language

FORMER SECRETARY. In this photo, then-incoming press secretary Trixie Cruz-Angeles says she and her team have been attending to transition concerns.

Rappler

(1st UPDATE) 'From the foregoing, it is clear that respondents employed language, which are grossly abusive and offensive, which are not befitting the dignity of the legal profession,' the SC says

MANILA, Philippines – The Supreme Court (SC) imposed a six-month suspension on former Malacañang spokesperson Trixie Cruz-Angeles for violation of the Code of Professional Responsibility (CPR), the old code of conduct for lawyers.

In a decision uploaded on July 18, the SC found Angeles and another respondent, Ahmed Paglinawan, guilty of violating Rule 8.01, Canon 8 of the old lawyers’ code of conduct. The High Court also “sternly warned” the two that a repetition of the act they committed will be dealt more severely.

“From the foregoing, it is clear that respondents employed language, which are grossly abusive and offensive, which are not befitting the dignity of the legal profession. Hence, the imposition of disciplinary liability is warranted,” the SC said.

In its ruling, the SC said it found no reason to depart from the findings of the Integrated Bar of the Philippines (IBP), which found the respondents guilty. The High Court said the respondents did not also dispute that they made the statements that were mentioned.

“Notably, such use of intemperate language is considered a violation of the Code of Professional Responsibility, particularly Rule 8.01, Canon 8,” the SC said. 

The SC added that although the subject statements were made during judicial proceedings, the High Court agreed with the findings of the IBP that “such statements are irrelevant to the unlawful detainer case, and thus, cannot be considered as privileged communication.”

The High Court also took note of Angeles’ earlier suspension: “She had also been previously suspended from the practice of law. Hence, the imposition of suspension from the practice of law for a period of six months is in order.”

In 2016, the SC imposed a three-year suspension against Angeles over a complaint filed against her in 2003. The SC found the former press secretary guilty of violating the lawyer’s code of conduct over an allegation that she refused to return the money when her client demanded a refund. 

What happened before

On May 10, 2016, lawyer Roderick Manzano filed a complaint against Angeles and Paglinawan, and prayed that they be disbarred for violation of the lawyer’s code of conduct. Manzano accused the lawyers of violating the code for using “grossly abusive, offensive, and improper language” in a pleading they filed. 

In his complaint, Manzano said Angeles and Paglinawan made the following statements, among others: 

“She (Manzano’s client) is an INC patsy. She is Eduardo Manalo’s pawn.”

“FIRST, BOGUS. Plaintiff is an incorrigible liar.”

“Oppressive, truly. A glimpse of Marcosian martial law, perhaps, xxx”

“xxx They can be anyone, even Plaintiff’s own henchmen. They were already used elsewhere. They are in fact pictures of Plaintiffs hired help, who like their supposed witness, who would not dare defying Plaintiffs wishes, despotic and depraved as they are at the risk of being ‘MATIWALAG.”‘

The SC later issued a notice, referring the case to the IBP Commission on Integrity and Bar Discipline (CBD) for investigation and recommendation. On July 25, 2018, the IBP-CBD issued its recommendation, which suggested that Angeles and Paglinawan should be suspended from law practice for six months. 

The IBP Board of Governors later adopted the IBP-CBD’s recommendation. The lawyers filed a motion for reconsideration, asking the IBP board to reconsider its decision. The IBP board later modified its decision and changed the decision on Paglinawan from suspension to reprimand. – Rappler.com

1 comment

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  1. ET

    Deep appreciation to this action from the Supreme Court. So, now, lawyers should watch their language and behavior.

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Jairo Bolledo

Jairo Bolledo is a multimedia reporter at Rappler covering justice, police, and crime.