As a law alumnus of the Institute of Law of Far Eastern University (FEU), Manila, I feel proud for the vigilance of FEU law students who initiated B.M. 1217, January 18, 2005 (Rolando O. Eco, et al. vs. John L. Choa.), where the Philippine Supreme Court held the respondent John L. Choa in contempt of court and fined him Fifty Thousand Pesos (P50,000.00), with imprisonment until full payment, for misrepresenting himself as an “Atty.” in his social and business dealings.
Let me digest the said decision.
At issue was the alleged unauthorized and contumacious use by respondent John L. Choa of the title "Atty." without having actually been admitted to the Philippine bar.
The complainants were students of the Far Eastern University (FEU) Institute of Law who learned that respondent has been holding himself out as a lawyer for many years without obtaining a license from the Supreme Court to practice law. Complainants likewise alleged that respondent has been advertising the name of his supposed law firm, Choa Montilla Albeza & Associates Law Offices, with himself as senior partner. As President of the Printing Industries Association of the Philippines (PIAP), respondent was also misrepresenting himself as a full-fledged lawyer by signing the official documents of the PIAP as "Atty. John L. Choa."
Putting up a lame and ridiculous excuse, in his Comment, the respondent admitted the use of "Atty." although he was not a member of the bar. He explained that he did so in good faith, believing that the title is synonymous with the word "lawyer," hence, "he could use said title." He stated that he never engaged in the practice of law and the firm he was connected with never practiced law. Now that he realized that the word "attorney" has a technical and legal meaning, reserved only for those who are licensed by the Supreme Court to practice law, respondent has informed the Court that he is voluntarily desisting from using the title since the filing of this complaint.
Respondent, although a law graduate of the FEU Institute of Law, never took the bar. He had no right to use the title "Atty." which others have earned through rigorous and serious effort. Likewise, he had no right to represent himself as a law practitioner with a law firm under his name.
The Court held that the respondent's defense that he used the title "Atty." in good faith did not exonerate him from liability. Respondent should know that a mere law graduate was not entitled to use the title "Atty." and practice law unless and until he passes the bar and meets the requirements of the Rules of Court. Lastly, his voluntary desistance from using the title did not mitigate his liability either. Falsely claiming to be an attorney and acting as such without authority constitutes contempt of court. (See Rule 138 in relation to Rule 71, Rules of Court)
