1.

WHAT ARE THE 10 THINGS TO AVOID AS AN ESTEEMED LEGAL

COUNSELLOR? EXPLAIN
A. Avoid soliciting clients and/or ambulance-chasing.
Ambulance chasing is prohibited and any person who commits such act is
criminally and civilly liable.

B. Avoid conflicts of interest

Conflict of interest must be avoided so that the paramount needs of the client will
be promoted. There should be no conflict of interest in handling a client to
prevent dishonesty that may prejudice the rights of the client.

C. Avoid commercial advertising of legal skills and talents.

Lawyering is not a commercial profession. Hence, commercial advertisement
must be avoided. The practice of law should not be considered as a business.

D. Avoid facilitating or entering into champertous contracts.

A champertous contract is where a  lawyer stipulates with his client that in the
prosecution of the case, he will bear all the expenses for the recovery of things or
property being claimed by the client and the latter agrees to pay the former a
portion of the thing/property recovered as compensation.

E. Avoid disclosing privileged communication.

A lawyer shall preserve the confidences and secrets of his client even after the
attorney-client relation is terminated. An attorney cannot, without the consent of
his client, be examined as to any communication made by the client to him, or his
advice given thereon in the course of professional employment; nor can an
attorney’s secretary, stenographer, or clerk be examined, without the consent of
the client and his employees, concerning any fact the knowledge of which has
been acquired in such capacity

F. Avoid abetting unauthorized practice of law by non-lawyers.

 By aiding the unauthorized practice of law by non-lawyers, the lawyer promotes
injustice. Hence, it is important that the practice of law by non-lawyers when not
authorized should not be tolerated because it only prejudices the interest and
welfare of the public.

G. Avoid using vulgar, disrespectful and intemperate language especially in court

pleadings.
By avoiding disrespectful and vulgar language, it will only show how a lawyer
respects the court. It is important that lawyers show utmost respect to the court
and its officers.

H. Avoid forum-shopping and/or filing multiple suits.

Forum-shopping should be avoided. Forum shopping is the institution of two or
more suits in different courts, either simultaneously or successively, in order to
ask the courts to rule on the same or related causes and/or to grant the same or
substantially the same reliefs. It is an act of malpractice that is prohibited and
condemned because it trifles with the courts and abuses their processes. It
degrades the administration of justice and adds to the already congested court
dockets

I. Avoid filing any suit for money or malice.

Lawyering is not a business. Judicial services and processes should not be used
for personal interest and motive such as money.

J. Avoid committing any act of moral turpitude, gross immorality, dishonesty, and/or
any affair, transaction or practice that is repugnant to the Lawyer’s Oath.
The Lawyer’s Oath should be upheld by all the lawyers. Actions in contravention
with the Lawyer’s Oath should be avoided by lawyers.

2. HOW DO YOU BILL A CLIENT?

A counsel should bill a client based on different factors. These factors include:
A. The nature of the case involved
B. The difficulty and intricacy of the legal issues as compared to simple cases
C. The time and effort to be invested from the drafting of the pleadings to the
commencement of the litigation in court, the projected and number of court
appearance up to its termination in the trial court
D. Other unexpected incidents like filing and arguing a motion, the estimated time
and effort to be spent for argumentation
E. In case of appeal, the expenses incurred in perfecting an appeal, preparation of
appeal briefs, and additional amount of attorney’s fees for the purpose of appeal.
These factors will allow the client to determine the amount of the bill
proportionate to the legal services that he will fulfill.

3. WHAT ARE THE CONTENTS OF A CONTRACT OF LEGAL SERVICES?

EXPLAIN.
A. The parties to the contract of legal services.
B. Entry into the client contract
C. Procedure for provision of services
D. Fees and charges to be paid for services
E. Other rights and obligations of the client
F. Rights and obligations of the law firm
G. Liability in case of breach
H. Termination of contract
I. Other miscellaneous provisions
4. HOW DO YOU ATTRACT AND MAINTAIN CLIENTS? EXPLAIN

The actions and manner by which a lawyer treats his clients are important in
attracting and maintaining positive relationship with a client. The lawyer should
endeavor to protect and take good care of his relationship with his client by treating
the client with:
a. Cordiality and Compassion
b. Sincerity and Honest Intentions
c. Spirit of not giving when all the odds seem to shatter the brightest hopes.
 By making a client happy and comfortable, a lawyer can attract and maintain
clients. The lawyer should also ensure to make the client happy and comfortable by:
a. Remembering who you are working for since the real boss is the client.
b. Defining the relationship by making sure the client understands everything
c. Keeping in touch by giving the clients updates.
d. Keeping at least two docketing systems for personal management and the one
that the staff manages.
e. Accepting phone calls so that you will be accessible to clients and be of service.
f. Promptly returning phone calls by telling your staff that you call clients back.
g. Giving the clients copy of everything.
h. Avoiding procrastination and handle the necessary matters as soon as possible.
i. Sending out evaluation sheet to ask the client to evaluate your performance after
the case to determine areas of your service that must be improved.
By possessing the characteristics that clients look from lawyers, the latter will be
able to attract the former. The characteristics that clients look from lawyers are:
a. Friendliness
b. Promptness
c. Courtesy
d. Respect for clients
e. Business like attitude
f. Consideration in keeping clients informed.

To maintain good relationship and attract clients, it is important to keep the

clients happy by:
a. Avoiding unnecessary delay
b. Keeping your client informed
c. Being there when your client wants and needs you
d. Looking out for your client’s interests
e. Looking as effective as your are.

In order to attract clients, it is important for a lawyer to possess the following:

 a. Good reputation for capability as a lawyer
b. Reputation for trustworthiness
c. Personal acquaintance with the client
d. Referral by neighbor or friend
e. Participation in civic, religious and community activities
f. Referral by another lawyer
g. Lawyer’s political activity
h. Lawyer’s Appearance and conduct in Court

5. WHAT ARE THE OPTIONS THAT A NEOPHYTE LAWYER MAY PURSUE?

EXPLAIN EACH.
A. Solo Private Practice
A solo practitioner starts from scratch, will most likely to be unable
to meet the souring cost of office rentals, equipment, travel and
representation. While a solo practitioner enjoys the advantage of being his
own boss and is not accountable to anyone except himself, yet not being
able to establish a name for himself in his initial practice, oftentimes finds
difficulty in attracting good paying clients.

B. Assistant or Associate in a private law firm

It offers better opportunities. This could be attained by organizing a
law firm among your classmates or by joining into a partnership with some
familiar friend lawyers who are well-to-do and financially capable of
satisfying the overhead expenses of maintaining a law office. It is
advisable that the partnership agreement be reduced to writing as the
partnership expands and progresses to avoid future misunderstanding.

C. Joining a corporate law department

It offers higher salary and doles out generous pecuniary and fringe
benefits not usually enjoyed from a private law firm. The disadvantage lies
in the fact that once a lawyer has stuck up with a corporate legal position,
 he finds it difficult to go into private practice later on for fear of losing a
higher paying job.

D. Government employment
Those who are already in the service before taking the bar, simply
utilize their profession for further promotion to higher positions in the
offices and agencies in which they are already employed. The
disadvantage however is that once you get stuck to your job with a well-
paying salary, you find it difficult to leave the same employment which
guarantees your future security like being entitled to a GSIS pension upon
retirement. The better option therefor for those who intend to pursue
private law practice, is to seek government employment for the purpose of
acquiring specialization and experience in specific fields like immigration
cases, insurance, tax cases and labor cases and after a stint of five years,
be more prepared to establish own law firm.

6. HOW AND WHEN DO YOU REJECT A CLIENT? EXPLAIN.

Rule 14.03 of the Code of Professional Responsibility treats the circumstances when
may a lawyer reject a client.

Rule 14.03 – A lawyer may refuse to accept representation of a client if:

1. a.      He is not in position to carry out the work effectively and competently.
2. b.     He labors under conflict of interest between him and the prospective
client or between a present client and the prospective client.
Based from this rule, a lawyer may reject to represent a client based on just cause. If
the lawyer knows that he is not in proper position to successfully carry out his duties as
a counsel, he can refuse the employment of the client. Furthermore, if there is an
existing conflict of interest between him and the possible client, he may refuse to accept
representation. In addition, if there is an existing conflict of interest between his present
client and prospective client, it is also a justifiable cause to reject a client. Conflict of
interest may affect the performance of the lawyer in fulfilling his legal duties to his
clients. Conflict of interest is a valid ground for a lawyer to refuse employment since it
may prejudice the client.
7. WHEN AND HOW TO WITHDRAW FROM A CASE? EXPLAIN.

A lawyer may withdraw his services under any of the following circumstances:
a. When client pursues an illegal or immoral course of action in connection with the
matter he is handling

If there is tendency that the client will pursue unlawful actions, the lawyer may
withdraw from the case. Since the duty of the lawyer is to carry out the cause of
his clients within the bounds of the law, he is given the right to withdraw from a
case if his client will be the one to manifest actions that are illegal and immoral.

b. When the client insists that the lawyer pursue a conduct violative of the canons
and rules of Professional Responsibility

The canons and rules of Professional Responsibility should be upheld by

lawyers to ensure that the integrity and quality of the legal profession will not be
tainted with negative reputation. If the client would be the one to insist for the
lawyer to violate the Code of Professional Responsibility of the lawyers, the latter
can be justified in withdrawing from a case. Violation of the provisions of the
Code of Professional Responsibility can be a ground of disbarment. Hence, it is
only reasonable that a lawyer may desist from pursuing the cause of his client, if
the latter will be insisting the violation of this code.

c. When his inability to work with co-counsel will not promote the best interest of the
client

There are instances that a lawyer needs to work with other lawyers as the
counsel of the client. Working with other lawyers requires positive working
relationship in order to promote the best interest of the client. Hence, if the lawyer
 will only prejudice the interest of the client while working with co-counsel, it would
be better to withdraw from the case. The withdrawal of a lawyer from a case
because of his inability to work with co-counsel will be justified if such inability will
not promote the best interest of the client. Basically, the counsel must give
paramount importance to the interest of the client. If issues would only negatively
affect the interest of the client, the counsel may refrain from accepting the
employment.

d. When the mental or physical condition of the lawyer renders it difficult for him to
carry out the employment effectively

If the lawyer is not in the best condition to pursue the cause of his client,
he may withdraw from the case. Furthermore, legal services may include
attending to trials, preparation of pleadings, motions, and appeals. Hence, it will
require that the lawyer will exert time and effort in fulfilling his duties. If the
lawyer, is not in the proper condition, mentally and physically to carry out his
functions, it is better to withdraw from the case to prevent prejudicial impacts to
his client.

e. When the client deliberately fails to pay the fees for the services or fails to
comply with the retainer agreement
A retainer agreement is a contract between the lawyer and his client. A
retainer agreement constitutes bilateral obligations on the part of the lawyer and
client. It means that both of them have obligations that must be fulfilled. On the
part of the lawyer, he shall carry out his legal duties to preserve the right of his
client within the bounds of the law. On the other hand, the client is obligated to
pay for the services to be rendered by the client for his benefit. Hence, if the
client fails to pay the fees or fails to comply with the terms of the retainer
agreement, a lawyer may withdraw from the case. The failure of the client to
comply with the retainer agreement is a justifiable ground for the lawyer to
withdraw from the case of his client.
f. Other similar cases

8. UP TO WHAT EXTENT IS THE AUTHORITY OF A LAWYER TO HIS CLIENT?

The lawyer has the authority to choose the proceedings he will institute
and the witnesses he will present in court. He can make admissions of fact but
not of law. The mistakes of the lawyer cannot be utilized as grounds for a new
trial unless it is shown that the incompetency of the counsel is so serious that his
client is prejudiced and was prevented from fairly presenting his case. An
attorney cannot bind his client by entering into an agreement compromising and
settling the rights of the client without special authorization.

9. HOW DO YOU CONDUCT A CLIENT INTERVIEW? EXPLAIN.

The interview must be all-embracing and exhaustive as possible. A lot of
psychology should be applied when having a face-to-face conversation with the
client. It is also important to avoid interrupting the client in communicating its
cause and other facts necessary. It is also important that the interview will be
conducted to know the truth.
The lawyer should also be firm and frank to the client. The lawyer and not
the client must be in control of the situation. It is important to be blunt to the client
so that the latter will be telling only the truth to avoid pursuing other legal course
not necessary.
The lawyer should also interview the client using the language that the
latter speaks. Basically, this will help in overcoming language barrier that may
result to miscommunication. Also, if the client can freely communicate his cause
using the language that he is confident with, it will be easier for the lawyer to
understand the situation. Hence, the lawyer will be able to make appropriate
action and decision.
Keep an interview with a client in private and outline your proposed course
of action. The interview with the client must be made in a private manner so that
the client will not be hesitant to share his cause. From there, the lawyer must be
 able to prepare course of action relevant to the interest of the client. From the
facts stated by the client, the lawyer must determine the needs and priorities of
the clients.

10. DIGEST THE CASES OF:

 Lahm v. Mayor, A.C. No. 7430, February 15, 2012

FACTS:

On 5 September 2006, a certain David Edward Toze filed a complaint for illegal
dismissal before the Labor Arbitration Branch of the National Labor Relations
Commission against the members of the Board of Trustees of the International School,
Manila. The case was raffled to the sala of the respondent, Labor Arbiter Jovencio Ll.
Mayor, Jr. During the proceedings, Toze filed a Verified Motion for the Issuance of a
Temporary Restraining Order and/or Preliminary Injunction, to which the complainants,
Martin Lahm III and James P. Concepcion, opposed. Thereafter, the respondent issued
an Order directing the parties in the said case to maintain the status quo ante, which
consequently reinstated Toze to his former position as superintendent of the
International School Manila. Despite the complainants’ motion for an early resolution of
their motion to dismiss the said case, respondent maintained his Order. Thus, the
complaint praying for the respondent’s disbarment for alleged gross misconduct and
violation of lawyer’s oath.
ISSUE:

Is the respondent guilty for the gross misconduct and violation of lawyer’s oath?

HELD:

Yes. The Supreme Court concurred with the conclusion of the Investigating
Commissioner of the IBP Commission on Bar Discipline that respondent guilty for the
gross misconduct and violation of lawyer’s oath. Gross misconduct is any inexcusable,
shameful or flagrant unlawful conduct on the part of a person concerned with the
administration of justice; i.e., conduct prejudicial to the rights of the parties or to the right
determination of the cause. The motive behind this conduct is generally a premeditated,
obstinate or intentional purpose.

Under the 2005 Rules of Procedure of the NLRC, the labor arbiters no longer
have the authority to issue writs of preliminary injunction and/or temporary restraining
orders. However, the respondent, in violation of the said rule, vehemently insist that he
has the authority to issue writs of preliminary injunction and/or temporary restraining
order.

Further, the unfounded insistence of the respondent on his supposed authority to

issue writs of preliminary injunction and/or temporary restraining order, taken together
with the delay in the resolution of the said motion for reconsideration, would clearly
show that the respondent deliberately intended to cause prejudice to the complainants.

In stubbornly insisting that he has the authority to issue writs of preliminary injunction
and/or temporary restraining order contrary to the clear import of the 2005 Rules of
Procedure of the NLRC, the respondent violated Canon 1 of the Code of Professional
Responsibility which mandates lawyers to obey the laws of the land and promote
respect for law and legal processes.
  Dacanay v. Baker & McKenzie, A.C. No. 2131, May 1985

FACTS: 
Atty. Dacanay sought to enjoin Juan Collas and nine other lawyers from
practicing law under the name Baker and McKenzie, a law firm organized in Illinois. In
1979 respondent Vicente A. Torres used the letterhead of Baker & McKenzie which
contains the names of the ten lawyers asking Rosie Clurman for the release of 87
shares of Cathay Products International, Inc. to H.E. Gabriel, a client. Atty. Dacanay
replied denying any liability of Clurman and asking the lawyer his purpose of using the
letterhead of another law office.

ISSUE: 
Whether or not respondents should enjoin from practising law under the firm
name Baker & McKenzie. 

HELD: 
YES. Baker & McKenzie, being an alien law firm, cannot practice law in the
Philippines (Sec. 1, Rule 138, Rules of Court).

 Who may practice law. -  Any person heretofore duly admitted as a member
of the bar, or hereafter admitted as such in accordance with the provisions of
this rule, and who is in good and regular standing, is entitled to practice law.

Respondents' use of the firm name Baker & McKenzie constitutes a

representation that being associated with the firm they could "render legal services of
the highest quality to multinational business enterprises and others engaged
in foreign trade and investment" which the Court finds unethical because Baker &
McKenzie is not authorized to practise law here.

WHEREFORE, the respondents are enjoined from practising law under the firm
name Baker & McKenzie.

 Dulalia v. Cruz, A.C. No. 6854, April 27, 2004

FACTS:

Susan Soriano Dulalia (Susan), wife of Juan, applied for a permit in the Municipal
Government to build a high rise building in Bulacan. The permit was not released due to
the opposition of Atty. Cruz who sent a letter to the Municipal Engineers office, claiming
that the building impedes the airspace of their property which is adjacent to the Dulalia’s
property. Juan Dulalia (Juan) filed a complaint for disbarment against Atty. Pablo Cruz
(Cruz) for immoral conduct.

Juan also claimed that Cruz’s illicit relationship with a woman while still married is
in violation of the Code of Professional Responsibility. Cruz invokes good faith, claiming
to have had the impression that the applicable provision at the time was Article 83 of the
Civil Code, for while Article 256 of the Family Code provides that the Code shall have
retroactive application, there is a qualification.

ISSUE:

Whether or not Cruz violated the Code of Professional Responsibility

HELD:
 Cruz’s claim that he was not aware that the Family Code already took effect on
August 3, 1988 as he was in the United States from 1986 and stayed there until he
came back to the Philippines together with his second wife on October 9, 1990 does not
lie, as “ignorance of the law excuses no one from compliance therewith.”

Immoral conduct which is proscribed under Rule 1.01 of the Code of Professional
Responsibility, as opposed to grossly immoral conduct, connotes “conduct that shows
indifference to the moral norms of society and the opinion of good and respectable
members of the community.” Gross immoral conduct on the other hand must be
so corrupt and false as to constitute a criminal act or so unprincipled as to be
reprehensible to a high degree.

It must be emphasized that the primary duty of lawyers is to obey the laws of the
land and promote respect for the law and legal processes. This duty carries with it the
obligation to be well-informed of the existing laws and to keep abreast with
legal developments, recent enactments and jurisprudence. It is imperative that they be
conversant with basic legal principles. Unless they faithfully comply with such duty, they
may not be able to discharge competently and diligently their obligations as members of
the bar. Worse, they may become susceptible to committing mistakes.

The Court therefore concludes that Atty. Pablo C. Cruz is guilty of violating Rule 1.01
and Canon 5 of the Code of Professional Responsibility and is suspended from the
practice of law for one year.

 Sanchez v. Atty. Torres, A.C. No. 10240, Nov. 25, 2014

FACTS: 
On 08 February 2007, complainant lend PhP 2,200,000.00 to the respondent.
The respondent issued to checks amounting to PhP 2,200,000.00 to the complainant
and promised to pay the loan within a month with interest. After a month’s time, the
respondent failed to pay the complainant. The respondent told the complainant to
deposit the checks and assured her that the checks will be honored. On 2 May 2008,
complainant to deposit the checks to her account, but the same were returned due to
‘Account Closed.’

    Despite repeated demands for the last three years, the complainant has yet to
pay his obligations  since the complainant sought legal assistance. Formal demand
letters were sent by the complainant’s lawyer which the respondent received on 14
August 2008 and 17 November 2008, respectively, and the same proved futile as the
respondent failed and refused to pay his obligation. Nonetheless, the respondent, in his
letter dated 9 May 2009, promised to pay anew his loan in cash on or before 15 May
2009 as replacement for the two checks he previously issued. But no payment was
made. Hence, the instant complaint was filed on 28 November 2011 at the IBP-CBD. It
ordered the respondent to file an answer. After giving ample time for the respondent to
answer to no avail, the IBP-CBD issued its report and recommendation dated 15 June
2012, finding the respondent guilty of willful dishonesty and unethical conduct for failure
to pay just debt and for issuing checks without sufficient funds. The respondent was
recommended to be sanctioned with suspension from practice of law for at least two
years. The IBP-Board of Governors adopted and approved the IBP-CBD’s report and
recommendation, and further ordered the return of loan amounting to PhP 2,200,000.00
to the complainant with legal interest.

 ISSUE:
Whether or not the respondent is guilty of violating the Code of Professional
Responsibility (CPR).

 HELD: 
The Supreme Court find the respondent violated Rule 1.01, Canon 1 of the CPR.

    With regards to the return of the amount of PhP 2,200,000.00 to the complainant,
the Supreme Court did not sustain it because in disciplinary proceedings against
lawyers, the only issue is whether the officer of the court is still fit to be allowed to
continue as a member of the Bar.

    It was noted that the respondent was already disbarred in CF Sharp Crew
Management v. Nicolas C. Torres for violating Rule 1.01, Canon 1 and Rules 16.01 and
16.03, Canon 16 of the CPR. The penalty of suspension or disbarment can no longer be
imposed. To resolve the instant case before the Court, the respondent was found guilty
of gross misconduct and violation of the CPR. The respondent is hereby suspended for
two years from the practice of law.

 Saladaga v. Atty. Astorga, A.C. No. 4697/4728, Nov. 25, 2014

FACTS:
Complainant Saldaga and respondent Atty. Astorga entered into a deed of sale
with right to repurchase on December 2, 1981. Atty. Astorga sold to the complainant a
parcel of coconut land located in Baybay, Leyte for 15,000.00. Under the deed, Saldaga
represented that it has “the perfect right to dispose as owner in fee simple” the subject
property, and that the property is “free from all liens and encumbrances”. The deed also
provided that Atty. Astorga, as vendor a retro, had two years within which to repurchase
the property, and if not repurchased, “the parties shall renew the instrument or
agreement”.  

Atty. Astorga failed to exercise his right to repurchase within the period stipulated
in the deed, and no renewal of contract was made when Saldaga made a final demand.
Saldaga remained in peaceful possession of the property until December 1989, he
received letters from Rural Bank of Albuera  (Leyte) informing him that the property is
mortgaged by Atty. Astorga to it. That the bank had foreclosed the property and
Saldaga should vacate the property. 
 Saldaga was dispossessed of the property, so it filed a case of estafa against the
respondent.  The complainant likewise instituted an administrative case which was then
referred to the IBP for  investigation, report  and recommendation, where it found Atty.
Astorga guilty of Bad Faith when he dealt with Saldaga misrepresenting him that the
property was covered with TCT No. T-662 when the said TCT
was  already  cancelled  earlier  and  transferred  to  her  wife’s  name  without  informin
g  Saldaga. It likewise held that Atty. Astorga shall be suspended from the practice of
law for two years and ordered to return the sum of 15,000 with interest.  

ISSUE:
WoN the investigating commissioner correctly ruled that the respondent be
suspended from the practice of law for two years and pay the corresponding amount.

HELD:
The Supreme Court ruled on the affirmative because when Atty. Astorga was
admitted to the legal profession, he took an oath to obey the laws, do no falsehood and
uphold the constitution, as well as to conduct himself as a lawyer according to the best
of his knowledge and discretion. This, in which he gravely violated his oath, when it
caused the ambiguity or vagueness in the Deed of Sale with Right to Repurchase as he
was the one who drafted or prepared such document. Respondent could have simply
denominated the instrument as a deed of mortgage and refer himself and the
complainant as “mortgagor” and “mortgagee”, rather than “vendor a retro” and “vendee
a retro”, then the controversy could have been avoided. His imprecise and misleading
wording of the said deed on its face betrayed the lack of legal competence on his part.
He thereby fell short of his oath, to conduct himself as a lawyer according to the best of
his knowledge and discretion.  
Indeed. respondent had the right to mortgage the property but as a lawyer, he
should have seen to it that the agreement faithfully, clearly and expressly embody or
reflect the intention of the parties. Otherwise, it will open the door to legal disputes
which in the case at bar was caused by respondent’s poor formulation of the “Deed of
Sale with Right to Repurchase”. Which played a significant factor in the controversy. 
            Likewise, the respondent dealt with the complainant with Bad Faith, Deceit and
Fraud when he made it appear that property was covered with TCT-662 when it was in
fact cancelled nine years earlier. Canon 1 and Rule 1.01 of the Code of Professional
Responsibility provides: 
CANON 1 – A lawyer shall uphold the constitution, obey the laws of the land and
promote respect for law and legal processes. 
Rule 1.01 – A lawyer shall not engage in unlawful, dishonest, immoral or deceitful
conduct.
          Under Canon 1, a lawyer is not only mandated to personally obey the laws and
the legal processes, he is moreover expected to inspire respect and obedience thereto.
On the other hand, Rule 1.01 states the norm of conduct that is expected of all lawyers.
Any act or omission that is contrary to, prohibited or unauthorized by, in defiance of,
disobedient to, or disregards the law is “unlawful.” “Unlawful” conduct does not
necessarily imply the element of criminality although the concept is broad enough to
include such element. The actions of respondent in connection with the execution of the
“Deed of Sale with Right to Repurchase” clearly fall within the concept of unlawful,
dishonest, and deceitful conduct. They also reflect bad faith, dishonesty, and deceit on
respondent’s part. 
Thus, respondent deserves to be sanctioned.