Solicitation of legal

services

Problem Areas in Legal Ethics

Arellano University School of Law – Arellano Law Foundation
2017-2018

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 Code of Professional Responsibility

• CANON 2 - A LAWYER SHALL MAKE HIS LEGAL SERVICES AVAILABLE

IN AN EFFICIENT AND CONVENIENT MANNER COMPATIBLE WITH
THE INDEPENDENCE, INTEGRITY AND EFFECTIVENESS OF THE
PROFESSION.

• Rule 2.01 - A lawyer shall not reject, except for valid reasons, the
cause of the defenseless or the oppressed.
• Rule 2.02 - In such cases, even if the lawyer does not accept a case,
he shall not refuse to render legal advice to the person concerned if
only to the extent necessary to safeguard the latter's rights.
• Rule 2.03 - A lawyer shall not do or permit to be done any act
designed primarily to solicit legal business.
• Rule 2.04 - A lawyer shall not charge rates lower than those
customarily prescribed unless the circumstances so warrant.

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 Code of Professional Responsibility
• CANON 3 - A LAWYER IN MAKING KNOWN HIS LEGAL SERVICES SHALL
USE ONLY TRUE, HONEST, FAIR, DIGNIFIED AND OBJECTIVE
INFORMATION OR STATEMENT OF FACTS.
• Rule 3.01 - A lawyer shall not use or permit the use of any false,
fraudulent, misleading, deceptive, undignified, self-laudatory or unfair
statement or claim regarding his qualifications or legal services.
• Rule 3.02 - In the choice of a firm name, no false, misleading or assumed
name shall be used. The continued use of the name of a deceased
partner is permissible provided that the firm indicates in all its
communications that said partner is deceased.
• Rule 3.03 - Where a partner accepts public office, he shall withdraw from
the firm and his name shall be dropped from the firm name unless the
law allows him to practice law currently.
• Rule 3.04 - A lawyer shall not pay or give anything of value to
representatives of the mass media in anticipation of, or in return for
publicity to attract legal business.

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 Rule 138

• Sec. 27. Attorneys removed or suspended by Supreme Court on

what grounds. - A member of the bar may be removed or
suspended from his office as attorney by the Supreme Court for
any deceit, malpractice, or other gross misconduct in such office,
grossly immoral conduct, or by reason of his conviction of a
crime involving moral turpitude, or for any violation of the oath
which he is required to take before admission to practice, or for a
wilfull disobedience of any lawful order of a superior court, or for
corruptly or wilfully appearing as an attorney for a party to a case
without authority so to do. The practice of soliciting cases at
law for the purpose of gain, either personally or through paid
agents or brokers, constitutes malpractice.

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 Rule 2.03 should be read in connection
with Rule 1.03 of the CPR
• Rule 2.03 - A lawyer shall not do or permit to be done any act
designed primarily to solicit legal business.

• RULE 1.03. A LAWYER SHALL NOT, FOR ANY CORRUPT MOTIVE

OR INTEREST, ENCOURAGE ANY SUIT OR PROCEEDING OR DELAY
ANY MAN’S CAUSE.

• This rule proscribes “ambulance chasing” (the solicitation of

almost any kind of legal business by an attorney, personally or
through an agent in order to gain employment) as a measure to
protect the community from barratry and champerty. -
Linsangan v. Atty. Tolentino, A.C. No. 6672, September 4, 2009

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 Do not “pirate” a client

• CANON 8 - A LAWYER SHALL CONDUCT HIMSELF WITH

COURTESY, FAIRNESS AND CANDOR TOWARDS HIS
PROFESSIONAL COLLEAGUES, AND SHALL AVOID HARASSING
TACTICS AGAINST OPPOSING COUNSEL.

• Rule 8.02 - A lawyer shall not, directly or indirectly, encroach

upon the professional employment of another lawyer, however, it
is the right of any lawyer, without fear or favor, to give proper
advice and assistance to those seeking relief against unfaithful or
neglectful counsel.

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 The following elements distinguish the legal
profession from a business:

• 1. A duty of public service, of which the emolument is a by-

product, and in which one may attain the highest eminence
without making much money;
• 2. A relation as an “officer of the court” to the administration
of justice involving thorough sincerity, integrity and reliability;
• 3. A relation to clients in the highest degree of fiduciary;
• 4. A relation to colleagues at the bar characterized by candor,
fairness, and unwillingness to resort to current business methods
of advertising and encroachment on their practice, or dealing
directly with their clients. - Atty. Khan Jr. v. Atty. Simbillo, A.C. No.
5299, August 19, 2003

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 General rule

• Hence, lawyers are prohibited from soliciting cases for the

purpose of gain, either personally or through paid agents or
brokers. Such actuation constitutes malpractice, a ground for
disbarment. - Linsangan v. Atty. Tolentino, A.C. No. 6672,
September 4, 2009

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• “Solicitation or obtaining of professional employment by any
means of communication." - Geffen v. Moss, 53 Cal.App.3d 215,
125 Cal.Rptr. 687 [1975]

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 Solicitation or Ambulance chasing

• We need not labor the point that solicitation or ambulance

chasing, so-called, either directly or indirectly through the
services of runners or others, is conduct which is reprehensible
and inimicable to the traditions and best interests of the legal
profession. Not only does it provoke derision and disrespect in
the eyes of the public, but it is an overreaching of the other
members of the profession who adhere to the standards fixed by
canons of ethics and the dictates of good conscience. To permit
such conduct to continue undeterred could only result in
unsavory competitions and consequences materially
detrimental to the dignity and honor of the legal profession as
a whole. - In re Krasner 204 N.E.2d 10 (1965)

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 Solicitation of a political organization
• Appellant, a practicing lawyer in South Carolina who was also a
cooperating lawyer with a branch of the American Civil Liberties
Union (ACLU), after advising a gathering of women of their legal
rights resulting from their having been sterilized as a condition of
receiving public medical assistance, informed one of the women in
a subsequent letter that free legal assistance was available from the
ACLU. Thereafter, the disciplinary Board of the South Carolina
Supreme Court charged and determined that appellant, by sending
such letter, had engaged in soliciting a client in violation of certain
Disciplinary Rules of the State Supreme Court, and issued a private
reprimand.

• Issue: WON the lawyer engaged in unethical solicitation.

 ……
• Solicitation of prospective litigants by nonprofit organizations
that engage in litigation as "a form of political expression" and
"political association" constitutes expressive and associational
conduct entitled to First Amendment protection, as to which
government may regulate only "with narrow specificity.”

• The "collective activity undertaken to obtain meaningful

access to the courts is a fundamental right within the
protection of the First Amendment." - In re Primus, 436 U.S. 412
(1978)
 Lawyer visited 2 accident victims
• He approached two young accident victims at a time when
they were especially incapable of making informed
judgments or of assessing and protecting their own
interests. He solicited [the victim] in a hospital room where
she lay in traction, and sought out [the other victim] on the
day she came home from the hospital, knowing from his
prior inquiries that she had just been released.
• Appellant urged his services upon the young women. He
employed a concealed tape recorder, seemingly to insure
that he would have evidence of [victim’s] oral assent to the
representation. He emphasized that his fee would come
out of the recovery, thereby tempting the young women
with what sounded like a cost-free and therefore irresistible
offer.
 ……
• Held: The Bar, acting with state authorization, constitutionally may
discipline a lawyer for soliciting clients in person, for pecuniary gain,
under circumstances likely to pose dangers that the State has a
right to prevent, and thus the application of the Disciplinary Rules in
question to appellant does not offend the Constitution.
• (a) A lawyer's solicitation of business through direct, in-person
communication with the prospective clients has long been viewed
as inconsistent with the profession's ideal of the attorney-client
relationship and as posing a significant potential for harm to the
prospective client.
• (b) The State does not lose its power to regulate commercial
activity deemed harmful to the public simply because speech is a
component of that activity.
• (c) A lawyer's procurement of remunerative employment is only
marginally affected with First Amendment concerns. While entitled
to some constitutional protection, [respondent's] conduct is subject
to regulation in furtherance of important state interests. - Ohralik v.
Ohio State Bar Assn., 436 U.S. 447 (1978)
 ……
• (d) In addition to its general interest in protecting consumers and
regulating commercial transactions, the State bears a special
responsibility for maintaining standards among members of the
licensed professions, especially members of the Bar. Protection of
the public from those aspects of solicitation that involve fraud,
undue influence, intimidation, overreaching, and other forms of
"vexatious conduct" is a legitimate and important state interest.

• (e) Because the State's interest is in averting harm by prohibiting

solicitation in circumstances where it is likely to occur, the absence
of explicit proof or findings of harm or injury to the person solicited
is immaterial. The application of the Disciplinary Rules to appellant,
who solicited employment for pecuniary gain under circumstances
likely to result in the adverse consequences the State seeks to
avert, does not offend the Constitution.
 Ambulance chasing

• This rule proscribes “ambulance chasing” (the solicitation of

almost any kind of legal business by an attorney, personally or
through an agent in order to gain employment) as a measure to
protect the community from barratry and champerty. - Linsangan
v. Atty. Tolentino, A.C. No. 6672, September 4, 2009

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 Champertous contract

• Champerty n. an agreement between the party suing in a lawsuit

(plaintiff) and another person, usually an attorney, who agrees to
finance and carry the lawsuit in return for a percentage of the
recovery (money won and paid.) In Common Law this was illegal
on the theory that it encouraged lawsuits.

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 Contingent fee is valid

• Contingent fee contracts are permitted in this jurisdiction

because they redound to the benefit of the poor client and the
lawyer "especially in cases where the client has meritorious cause
of action, but no means with which to pay for legal services
unless he can, with the sanction of law, make a contract for a
contingent fee to be paid out of the proceeds of litigation.
Oftentimes, the contingent fee arrangement is the only means by
which the poor clients can have their rights vindicated and
upheld."
• As long as the lawyer does not exert undue influence on his
client, that no fraud is committed or imposition applied, or that
the compensation is clearly not excessive as to amount to
extortion, a contract for contingent fee is valid and enforceable.
– Fabillo v. IAC G.R. No. L-68838 March 11, 1991

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 Acceptance fee

• An acceptance fee is not a contingent fee, but is an absolute fee

arrangement which entitles a lawyer to get paid for his efforts
regardless of the outcome of the litigation. - Yu v. Bondal, A.C.
No. 5534, January 17, 2005

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• Touters - someone who advertises for customers in an especially
brazen way.
• Common barratry consisting of frequently stirring up suits and
quarrels between individuals.

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 Only way to announce legal service

• For this reason, lawyers are only allowed to announce their

services by publication in reputable law lists or use of simple
professional cards. - Linsangan v. Atty. Tolentino, A.C. No. 6672,
September 4, 2009

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• Nonetheless, the solicitation of legal business is not altogether
proscribed. However, for solicitation to be proper, it must be
compatible with the dignity of the legal profession. If it is
made in a modest and decorous manner, it would bring no
injury to the lawyer and to the bar. - Atty. Khan Jr. v. Atty.
Simbillo, A.C. No. 5299, August 19, 2003

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• For this reason, lawyers are only allowed to announce their
services by publication in reputable law lists or use of simple
professional cards. Linsangan v. Atty. Tolentino, A.C. No. 6672,
September 4, 2009

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• Professional calling cards may only contain the following details:

(a) lawyer’s name;

(b) name of the law firm with which he is connected;
(c) address;
(d) telephone number and
(e) special branch of law practiced.
- Linsangan v. Atty. Tolentino, A.C. No. 6672, September 4, 2009

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 Brief biographical and informative data
• Such data must not be misleading and may include only the following:
1. a statement of the lawyer’s name and the names of his professional associates;
2. addresses, telephone numbers, cable addresses;
3. branches of law practiced;
4. date and place of birth and admission to the bar;
5. schools attended with dates of graduation, degrees and other educational
distinctions;
6. public or quasi-public offices;
7. posts of honor;
8. legal authorships;
9. legal teaching positions;
10. membership and offices in bar associations and committees thereof, in legal
and scientific societies and legal fraternities;
11. the fact of listings in other reputable law lists;
12. the names and addresses of references; and,
13. with their written consent, the names of clients regularly represented. - Atty.
Khan Jr. v. Atty. Simbillo, A.C. No. 5299, August 19, 2003

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 Acceptable law list publication

• The law list must be a reputable law list published primarily for
that purpose; it cannot be a mere supplemental feature of a
paper, magazine, trade journal or periodical which is published
principally for other purposes. For that reason, a lawyer may not
properly publish his brief biographical and informative data in a
daily paper, magazine, trade journal or society program. Nor may
a lawyer permit his name to be published in a law list the
conduct, management, or contents of which are calculated or
likely to deceive or injure the public or the bar, or to lower dignity
or standing of the profession. - Atty. Khan Jr. v. Atty. Simbillo, A.C.
No. 5299, August 19, 2003

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 Acceptable publication

• The use of an ordinary simple professional card is also permitted.

The card may contain only a statement of his name, the name of
the law firm which he is connected with, address, telephone
number and special branch of law practiced. The publication of a
simple announcement of the opening of a law firm or of
changes in the partnership, associates, firm name or office
address, being for the convenience of the profession, is not
objectionable. - Atty. Khan Jr. v. Atty. Simbillo, A.C. No. 5299,
August 19, 2003

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 Telephone directory

• He may likewise have his name listed in a telephone directory but

not under a designation of special branch of law. - Atty. Khan
Jr. v. Atty. Simbillo, A.C. No. 5299, August 19, 2003

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Whether or not the firm of Velasquez, Rodriguez,
Respicio, Ramos, Nidea, and Prado may call itself
“A law Firm Of St. Thomas More and Associate
Members”
• We agree with the OBC. Rule 3.02 is clear. No name not
belonging to any of the partners or associates may be used in
the firm name for any purpose. In one case, we have ruled that
the use of the firm name of a foreign law firm is unethical
because that firm is not authorized to practice law in this
jurisdiction. In this case, “The Law Firm of St. Thomas More and
Associate Members” is not a law firm in this jurisdiction or even
in any other jurisdiction. A “St. Thomas More and Associates” or
STMA is in fact the socio-political ministry or the couples for
Christ, a Christian family-renewal community. - PP v. Gonzalez, Jr.,
G.R. No. 139542 June 10, 2003

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 …..
• To appellate to the name of the lawyers “The Law Firm of St.
Thomas More and Associate Members” indeed appears
misleading. It implies that St. Thomas More is a Law Firm
when in fact it is not it would also convey to the public the
impression that the lawyers are members of the law firm which
does not exist. To the public, it would seem that the purpose or
intention of adding “The Law Firm of St. Thomas More and
Associates Members” is to bask in the name of a Saint, although
that may not really, be the purpose or intention of the lawyers.
The appellation only tends to confuse the public and in a way
demean both the saints and the legal profession whose
members must depend on their own name and record and merit
and not on the name/glory of other persons living or dead. – PP
v. Gonzalez, Jr., G.R. No. 139542 June 10, 2003

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Philippine Daily Inquirer, which reads:

“ANNULMENT OF MARRIAGE Specialist 532-4333/521-2667.”

- Atty. Khan Jr. v. Atty. Simbillo, A.C. No. 5299, August 19, 2003

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• Thus, the use of simple signs stating the name or names of the
lawyers, the office and residence address and fields of practice, as
well as advertisement in legal periodicals bearing the same brief
data, are permissible. Even the use of calling cards is now
acceptable. Publication in reputable law lists, in a manner
consistent with the standards of conduct imposed by the canon,
of brief biographical and informative data is likewise allowable. -
Atty. Khan Jr. v. Atty. Simbillo, A.C. No. 5299, August 19, 2003

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 Calling card of Atty. Tolentino
Front

NICOMEDES TOLENTINO

LAW OFFFICE

CONSULTANCY & MARITIME SERVICES

W/ FINANCIAL ASSISTANCE

Fe Marie L. Labiano

Paralegal

1st MIJI Mansion, 2nd Flr. Rm. M-01 Tel: 362-7820

6th Ave., cor M.H. Del Pilar Fax: (632) 362-7821

Grace Park, Caloocan City Cel.: (0926) 2701719

Back

SERVICES OFFERED:

CONSULTATION AND ASSISTANCE

TO OVERSEAS SEAMEN

REPATRIATED DUE TO ACCIDENT,

INJURY, ILLNESS, SICKNESS, DEATH

AND INSURANCE BENEFIT CLAIMS

ABROAD.

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 …..
• Complainant alleged that respondent, with the help of paralegal
Fe Marie Labiano, convinced his clients to transfer legal
representation. Respondent promised them financial assistance
and expeditious collection on their claims. To induce them to hire
his services, he persistently called them and sent them text
messages.
• To support his allegations, complainant presented the
sworn affidavit of James Gregorio attesting that Labiano tried to
prevail upon him to sever his lawyer-client relations with
complainant and utilize respondent’s services instead, in
exchange for a loan of P50,000.

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 …..
• Moreover, by engaging in a money-lending venture with his
clients as borrowers, respondent violated Rule 16.04:
• Rule 16.04 – A lawyer shall not borrow money from his client
unless the client’s interests are fully protected by the nature of
the case or by independent advice. Neither shall a lawyer lend
money to a client except, when in the interest of justice, he has
to advance necessary expenses in a legal matter he is handling
for the client. - Linsangan v. Atty. Tolentino, A.C. No. 6672,
September 4, 2009

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 …..
• The rule is that a lawyer shall not lend money to his client. The
only exception is, when in the interest of justice, he has to
advance necessary expenses (such as filing fees, stenographer’s
fees for transcript of stenographic notes, cash bond or premium
for surety bond, etc.) for a matter that he is handling for the
client.
• The rule is intended to safeguard the lawyer’s independence of
mind so that the free exercise of his judgment may not be
adversely affected. It seeks to ensure his undivided attention to
the case he is handling as well as his entire devotion and fidelity
to the client’s cause. - Linsangan v. Atty. Tolentino, A.C. No. 6672,
September 4, 2009

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 Lending money to client

• If the lawyer lends money to the client in connection with the

client’s case, the lawyer in effect acquires an interest in the
subject matter of the case or an additional stake in its outcome.
Either of these circumstances may lead the lawyer to consider
his own recovery rather than that of his client, or to accept a
settlement which may take care of his interest in the verdict to
the prejudice of the client in violation of his duty of undivided
fidelity to the client’s cause. - Linsangan v. Atty. Tolentino, A.C. No.
6672, September 4, 2009

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 Uninformative fact

• Somewhat more troubling is appellant's listing, in large capital

letters, that he was a member of the Bar of the Supreme Court
of the United States. The emphasis of this relatively
uninformative fact is at least bad taste. - In re: R.M.J. 455 U.S. 191
[1982]

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 Including a government lawyer in a
business card
• Thus, while he may not be actually and directly employed with
the firm, the fact that his name appears on the calling card as
a partner in the Baligod, Gatdula, Tacardon, Dimailig & Celera
Law Offices give the impression that he is connected therein and
may constitute an act of solicitation and private practice which
is declared unlawful under Republic Act No. 6713. - Samonte v.
Atty. Gatdula A.M. No. P-99-1292 [1999]

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 A verified complaint, sought to enjoin Juan G.
Collas, Jr. and nine other lawyers from practicing
law under the name of Baker & McKenzie, a law
firm organized in Illinois

• We hold that Baker & McKenzie, being an alien law firm, cannot
practice law in the Philippines (Sec. 1, Rule 138, Rules of Court).
As admitted by the respondents in their memorandum, Baker &
McKenzie is a professional partnership organized in 1949 in
Chicago, Illinois with members and associates in 30 cities around
the world. Respondents, aside from being members of the
Philippine bar, practicing under the firm name of Guerrero &
Torres, are members or associates of Baker & Mckenzie. -
Dacanay v. Baker & McKenzie, et. al. Adm. Case No. 2131 [1985]

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 …..
• As pointed out by the Solicitor General, 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“. This is unethical
because Baker & McKenzie is not authorized to practice law here.
- Dacanay v. Baker & McKenzie, et. al. Adm. Case No. 2131 [1985]

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 Director of Religious Affairs v. Bayot,
A.C. No. L-1117, March 20, 1944
• Sunday Tribune of June 13, 1943, which reads as follows:

Marriage license promptly secured thru our assistance & the

annoyance of delay or publicity avoided if desired, and marriage
arranged to wishes of parties. Consultation on any matter free for
the poor. Everything confidential.

Legal assistance service

12 Escolta, Manila, Room, 105
Tel. 2-41-60.

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 Admonition to a young lawyer

• "The most worth and effective advertisement possible, even for a

young lawyer, . . . is the establishment of a well-merited
reputation for professional capacity and fidelity to trust. This
cannot be forced but must be the outcome of character and
conduct.“ - Director of Religious Affairs v. Bayot, A.C. No. L-1117,
March 20, 1944

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 Unacceptable advertisement

LUIS B. TAGORDA
Attorney
Notary Public
CANDIDATE FOR THIRD MEMBER
Province of Isabela

(NOTE. — As notary public, he can execute for you a deed of sale for the
purchase of land as required by the cadastral office; can renew lost
documents of your animals; can make your application and final requisites
for your homestead; and can execute any kind of affidavit. As a lawyer, he
can help you collect your loans although long overdue, as well as any
complaint for or against you. Come or write to him in his town, Echague,
Isabela. He offers free consultation, and is willing to help and serve the
poor.)

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 Volunteer [legal] advice is malpractice

• It is unprofessional for a lawyer to volunteer advice to bring a

lawsuit, except in rare cases where ties of blood, relationship
or trust make it his duty to do so. Stirring up strife and
litigation is not only unprofessional, but it is indictable at
common law. - Canons of Professionals Ethics adopted by the
American Bar Association in 1908 and by the Philippine Bar
Association in 1917. Canons 27 and 28 of the Code of Ethics - In
re: Tagorda, 53 Phil. 37 (1929)

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 Your best advertisement as a lawyer

• We repeat, the canon of the profession tell us that the best

advertising possible for a lawyer is a well-merited reputation for
professional capacity and fidelity to trust, which must be
earned as the outcome of character and conduct.
• Good and efficient service to a client as well as to the community
has a way of publicizing itself and catching public attention. That
publicity is a normal by-product of effective service which is right
and proper. A good and reputable lawyer needs no artificial
stimulus to generate it and to magnify his success. He easily sees
the difference between a normal by-product of able service and
the unwholesome result of propaganda. - Ulep vs. Legal Clinic
223 SCRA 378

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 Prohibited advertisement or solicitation In re:
Tagorda, 53 Phil. 37 (1929)

• But solicitation of business by circulars or advertisements, or by

personal communications or interview not warranted by
personal relations, is unprofessional.
• It is equally unprofessional to procure business by indirection
through touters of any kind, whether allied real estate firms or
trust companies advertising to secure the drawing of deeds or
wills or offering retainers in exchange for executorships or
trusteeships to be influenced by the lawyer.
• Indirect advertisement for business by furnishing or inspiring
newspaper comments concerning the manner of their conduct,
the magnitude of the interest involved, the importance of the
lawyer's position, and all other like self-laudation, defy the
traditions and lower the tone of our high calling, and are
intolerable.

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 Best mode of advertisement

• The most worthy and effective advertisement possible, even for a

young lawyer, and especially with his brother lawyers, is the
establishment of a well-merited reputation for professional
capacity and fidelity to trust. This cannot be forced, but must be
the outcome of character and conduct. - In re: Tagorda, 53 Phil.
37 (1929)

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 Law firm with a foreign lawyer as partner
• In the year 1904 he made an arrangement with the defendant
Ney, a practicing attorney, to carry on business together, sending
out a circular signed "Ney & Bosque," stating that they had
established an office for the general practice of law in all the
courts of the Islands and that Bosque would devote himself
especially to consultation and office work relating to Spanish
law. The paper was headed "Law Office - Ney & Bosque. Juan G.
Bosque, juris consulto español - C.W. Ney, abogado americano."
• Since that time the defendant Bosque has not personally
appeared in the courts, and with one exception, occuring through
an inadvertance, papers from the office were signed not with the
firm name alone nor with any designation of the firm as
attorneys, but with the words "Ney & Bosque - C.W. Ney,
abogado.“ - U.S. vs. Ney and Bosque, 8 Phil. 146 (1907)

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 …..
• Moreover the firm circular in setting forth the establishment of an
office for the general practice of law in all the courts of the
Islands, amounted to an assertion of his right and purpose, not
effectively qualified by the addition that he would devote
himself to consultation and office work relating to Spanish
law.

• Rule 3.01 - A lawyer shall not use or permit the use of any false,
fraudulent, misleading, deceptive, undignified, self-laudatory or unfair
statement or claim regarding his qualifications or legal services.
• Rule 3.02 - In the choice of a firm name, no false, misleading or
assumed name shall be used. Xxx.

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Thank you for your attention!!

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