In re: 1989 IBP Elections
178 SCRA 398 October 6, 1989
FACTS:
An election of national officers of the IBP was held last June 3, 1989. The newly elected officers was set
to take their oath of office after the Supreme Court en banc However,disturbed by the widespread
reports received by some members of the Court from lawyers who had witnessed or participated in the
proceedings and the adverse comments published in the columns of some newspapers about the
intensive electioneering and overspending by the candidates, led by the main protagonists for the office
of president of the association, namely, Attorneys Nereo Paculdo, Ramon Nisce, and Violeta C. Drilon,
the alleged use of government planes, and the officious intervention of certain public officials to
influence the voting, all of which were done in violation of the IBP By-Laws which prohibit such activities.
The Supreme Court en banc, exercising its power of supervision over the Integrated Bar, resolved to
suspend the oath-taking of the IBP officers-elect and to inquire into the veracity of the reports.
It should be stated at the outset that the election process itself (i.e. the voting and the canvassing of
votes on June 3, 1989) which was conducted by the "IBP Comelec," was unanimously adjudged by the
participants and observers to be above board. What the Court viewed with considerable concern was
the reported electioneering and extravagance that characterized the campaign conducted by the three
candidates for president of the IBP.
The Court en banc formed a committee to investigate the veracity of the reports. A total of forty-nine
(49) witnesses appeared and testified in response to subpoenas issued by the Court to shed light on the
conduct of the elections.
ISSUES:
Whether or not the IBP By-laws were violated
RULING:
Yes, the IBP By-laws were violated. From all the foregoing, it is evident that the manner in which the
principal candidates for the national positions in the Integrated Bar conducted their campaign
preparatory to the elections on June 3, 1989, violated Section 14 of the IBP By-Laws and made a travesty
of the idea of a "strictly non-political" Integrated Bar enshrined in Section 4 of the By-Laws.
The candidates and many of the participants in that election not only violated the By-Laws of the IBP but
also the ethics of the legal profession which imposes on all lawyers, as a corollary of their obligation to
obey and uphold the constitution and the laws, the duty to "promote respect for law and legal
processes" and to abstain from 'activities aimed at defiance of the law or at lessening confidence in the
legal system" (Rule 1.02, Canon 1, Code of Professional Responsibility). Respect for law is gravely eroded
when lawyers themselves, who are supposed to be millions of the law, engage in unlawful practices and
cavalierly brush aside the very rules that the IBP formulated for their observance.
The unseemly ardor with which the candidates pursued the presidency of the association detracted
from the dignity of the legal profession. The spectacle of lawyers bribing or being bribed to vote one
way or another, certainly did not uphold the honor of the profession nor elevate it in the public's
esteem.
The Court hereby orders the IBP elections held on June 3, 1989 should be as they are hereby annulled,
relevant by-laws of IBP is hereby amended as per Court’s orders and new elections be held and persons
that were part of the June 3, 1989 elections are ineligible and may not present themselves as candidate
for any position.
