2015 Legal and Judicial Ethics, Q23

Atty. Billy, a young associate in a medium-sized law firm, was in a rush to meet the deadline for filing his appellant’s brief. He used the internet for legal research by typing keywords on his favorite search engine, which led him to many websites containing text of Philippine jurisprudence. None of these sites was owned or maintained by the Supreme Court. He found a case he believed to be directly applicable to his client’s cause, so he copied the text of the decision from the blog of another law firm, and pasted the text to the document he was working on. The formatting of the text he had copied was lost when he pasted it to the document, and he could not distinguish anymore which portions were the actual findings or rulings of the Supreme Court, and which were quoted portions from the other sources that were used in the body of the decision. Since his deadline was fast approaching, he decided to just make it appear as if every word he quoted was part of the ruling of the Court, thinking that it would not be discovered.
Atty. Billy’s opponent, Atty. Ally, a very conscientious former editor of her school’s law journal, noticed many discrepancies in Atty. Billy’s supposed quotations from the Supreme Court decision when she read the text of the case from her copy of the PhUippine Reports. Atty. Billy failed to reproduce the punctuation marks and font sizes used by the Court. Worse, he quoted the arguments of one party as presented in the case, which arguments happened to be favorable to his position, and not the ruling or reasoning of the Court, but this distinction was not apparent in his brief. Appalled, she filed a complaint against him.
a. Did Atty. Billy fail in his duty as a lawyer? What rules did he violate, if any? (2%)
b. How should lawyers quote a Supreme Court decision? (2%)

Quick check

What ethical duty under the CPRA does a lawyer violate by misquoting a Supreme Court decision to mislead the court?

How must a lawyer quote Supreme Court decisions in official court pleadings?

What is the effect of passing off a party's arguments quoted in a decision as the Supreme Court's actual ruling?

Does an approaching court deadline excuse a lawyer from verifying legal citations copied from internet blogs?

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Which official publication should lawyers use to verify the accuracy and exact text of Supreme Court decisions?

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1. Duty of Candor
Under Canon II, Section 8 of the Code of Professional Responsibility and Accountability, a lawyer shall not knowingly misquote, misrepresent, or mislead the court as to the contents of any statute, decision, or legal authority. A lawyer owes absolute candor, fairness, and honesty to the court as an officer of justice. Intentionally misleading the tribunal regarding jurisprudence erodes judicial efficiency and compromises the integrity of legal proceedings, subjecting the attorney to administrative disciplinary sanctions.

2. Quoting Judicial Decisions
Lawyers are strictly required to quote decisions of the Supreme Court verbatim, reproducing the exact wording, punctuation marks, capitalization, and formatting used by the Court. When referencing jurisprudence in pleadings, an attorney must carefully distinguish between the Court's actual ratio decidendi and the unendorsed arguments of party litigants. Passing off a party's arguments as judicial rulings constitutes deliberate misrepresentation and a breach of ethical duties owed to the court.

3. Unverified Legal Research
Relying on unverified third-party blogs or secondary internet sources for legal research does not excuse misquoting jurisprudence in official court pleadings. Approaching filing deadlines and time constraints do not justify submitting inaccurate or misleading legal citations to judicial tribunals. Lawyers are obligated to exercise due diligence by verifying legal authorities against official court publications, such as the Philippine Reports, prior to filing pleadings with the court.

About these questions and answers
The questions reproduced here are the official texts of the Philippine Bar Examinations, published by the Supreme Court. They are reproduced for study purposes.The suggested answers are the author’s own.

They are not official answers, have no connection with the Supreme Court, the Office of the Bar Confidant, or any bar review institution, and are not endorsed by any of them. Official answer keys, where released, should be preferred over anything here.Nothing on this page is legal advice, and reading it creates no lawyer-client relationship. Do not rely on any suggested answer in an actual legal matter. Consult counsel on your own facts.Suggested answers reflect the law and jurisprudence the author considers applicable as of the date shown.

Where a question comes from an earlier examination, the suggested answer applies the law as it now stands, which may differ from the law in force when the question was given, and may therefore differ from what would have been the correct answer at that time. Where the difference is material, the answer notes it.The practice scoring feature measures wording overlap with the suggested answer. It is not a grade, carries no official weight, and says nothing about whether your reasoning is sound.Errors are possible. If you find one, please tell me and I will correct it.Last reviewed: October 2026