REPUBLIC OF THE PHILIPPINES

Commission on Bar Discipline

Integrated Bar of the Philippines
Manila

ZENA B. BERNARDO,
EVANGELINE P.
HERNANDEZ, NONA D.
ANDAYA-CASTILLO,
NATIVIDAD DELA CRUZ
NATIVIDAD, JOSE MARI
TOMINES CALLUENG,
JENNIFER AIZA
SANTAOLAYA, FAITH
ANGELIE CATALAN, MARK
VINCENT LIM,
Complainants,
-versus- COMPLAINT NO. _________
For: Disbarment,
Violation of Rule 138 of Rules
LORENZO GADON, of Court
Respondent. and Code of Professional
Responsibility

x--------------------------------------------------------------------------------------x

VERIFIED COMPLAINT

PREFATORY STATEMENT

“I don’t care if I am disbarred. I will still eat delicious food and

live comfortably. I don’t depend on income from lawyering alone,
unlike some IBP officials,” lawyer Lorenzo Gadon said in a statement.
 NATURE OF THE PROCEEDING

This is a VERIFIED COMPLAINT submitted to the Honorable

Commission on Bar Discipline, Integrated Bar of the Philippines
pursuant to Rule 139-B, Rules of Court, and the Rules of Procedure
of the Commission on Bar Discipline, Integrated Bar of the Philippines
for the disbarment of LORENZO GADON, for GROSS
MISCONDUCT, GROSS IMMORAL CONDUCT AND VIOLATIONS
OF THE LAWYER’S OATH.

THE COMPLAINANTS

The complainants, having been duly sworn to in accordance

with law, hereby depose and state:

1. The complainants in the VERIFIED COMPLAINT are the

following:

a. ZENA B. BERNARDO, of legal age and with office

address at Regus Manila, 5/F Gateway Tower, General
Roxas Avenue cor. General Aguinaldo, Araneta Center,
Cubao, Quezon City;
b. EVANGELINE P. HERNANDEZ, of legal age and with
address at Hustisya, Rm. 3, 2/F, Erythrina Bldg, No. 1
Maaralin cor. Matatag, Barangay Central, Quezon City;
c. NONA D. ANDAYA-CASTILLO, of legal age and with
office address at 2055 Road 5, NDC Compound, Sta.
Mesa, Manila;
d. NATIVIDAD DELA CRUZ NATIVIDAD, of legal age and
with office address at NCCP, 879 EDSA cor. Quezon
Avenue, Quezon City;
e. JOSE MARI TOMINES CALLUENG, of legal age and
with office address at 1550 J. Fajardo St., Sampaloc,
Manila;
f. JENNIFER AIZA SANTAOLAYA, of legal age and with
office address at Block 37, Lot 56, Southern Heights 2
Subdivision, San Pedro, Laguna;
g. FAITH ANGELIE CATALAN, of legal age and with office
address at 276 Maria Payo St., Tondo, Manila;
h. MARK VINCENT LIM, of legal age and with office
address at Vinzons Hall, University of the Philippines
Diliman, Quezon Ciy.
 2. We are concerned citizens, activists, community workers,
mothers who are disgusted by the actions and words of the
respondent, and we believe he should be removed from the rolls of
the legal profession.

3. Most of us were present during the incident in Baguio

City, in which the respondent hurled invectives and flashed the dirty
finger against a group of supporters of Chief Justice Maria Lourdes
Sereno.

4. We have also seen news reports on television,

newspapers, radio, internet regarding the same action and
statements of the respondent.

5. We have also monitored the negative public reaction

created by the respondent words and actions in Baguio City.

6. Notices and other processes from this Honorable

Commission may be served at Hustisya Office, Rm. 3, 2/F, Erythrina
Bldg, No. 1 Maaralin cor. Matatag, Barangay Central, Quezon City;

7. We are filing an administrative complaint against

respondent Lorenzo Gadon for gross misconduct, gross immoral
conduct and violation of his oath as a lawyer and the Code of
Professional Responsibility, on two instances:

a. On 10 April 2018, Mr Gadon flashed the dirty finger and

publicly cursed supporters of Chief Justice Maria Lourdes
Sereno outside the Supreme Court in Baguio City, during the
quo warrant proceedings against the Chief Justice;

b. In March 2016, Mr Gadon made hateful remarks against

Filipino Muslims during an interview conducted by GMA News
TV.
 STATEMENT OF FACTS

10 April 2018 incident

8. On 10 April 2018, Mr Gadon made the following

statement against supporters of Chief Justice Sereno outside the
Supreme Court in Baguio City, and in front of the media –

MR GADON: Ikaw bobo, putangina mo ka!

Kinanginamo!

9. In the same incident, he also made the following

statement –

MR GADON: Mga bobo! Mga bobo!

10. In the same incident, he flashed the dirty finger against

supporters of Chief Justice Sereno, as can be seen in this picture –

11. These statements and actuations appear to be made by a

madman unfit to be representing the legal profession.
 12. The public response over his actions has been nothing
but outrage.

13. The following tweet, by Law Students of Manila

(LawStdntsofMNL) is an example:

14. Nonetheless, Mr Gadon has been unapologetic over his

actions in Baguio, even taking a swipe against officials of the
Integrated Bar of the Philippines and threatening disbarment
proceedings against them, stating –

MR GADON: I dont care if I am disbarred , I wil stil

eat delicious food and live comfortably , I dont
 depend on income from lawyering alone unlike
some ibp officials (sic) (Emphasis supplied.)

xxx

MR GADON: I will also file diabarment case

agaisbt any IBP official for supporting sereno.
Because their act of support can be considered as
abetting the illegal acts of Sereno , they are
upholding the violation of the constitution by sereno
therefore they are also liable for violating the code of
ethics (sic) (Emphasis supplied.)

xxx

March 2016 incident

15. On the other hand, Mr Gadon made the following remarks

against Filipino Muslims during an interview with GMA News TV,
stating –

MR GADON: Sampung beses akong luluhod sa

(Moro Islamic Liberation Front para huwag nang
manggulo), iiyak ako ng bato at dugo, kapag
labing-isang pagkakataon at tumanggi pa rin
sila, lulusubin ko sila doon at dadalhin ko ang
buong sandatahang Pilipinas at papatayin ko
silang lahat, susunugin ko ang bahay nila.
Burahin ang lahi nila, kahit masunog ang
kaluluwa ko sa impiyerno gagawin ko 'yan
(Emphasis supplied.)

16. His anti-Muslim statement has also prompted two Muslim

lawyers, Algamar Latiph and Musa Malayang to file for disbarment
proceedings against Mr Gadon in the Supreme Court in April 2016 for
improper conduct.

17. In fact, as late as October 2017, the same complaining

Muslim attorneys had been seeking the continuation of the
disbarment case they have filed against Mr Gadon.
 18. With his latest hysterics, we are adding our names as
among those calling for his disbarment.

GROUNDS FOR THE ALLOWANCE OF THE VERIFIED

COMPLAINT

19. Due to the foregoing facts, It is our most respectful

position that these actions by Mr Gadon are in violation of the
following:

a. Section 20, Rule 138, Rules of Court –

xxx
Section 20. Duties of attorneys. — It is the duty
of an attorney:
xxx

(f) To abstain from all offensive personality

and to advance no fact prejudicial to the honor or
reputation of a party or witness, unless required
by the justice of the cause with which he is
charged; (Emphasis supplied.)
xxx

b. Rule 7.03, Code of Professional Responsibility –

Rule 7.03 - A lawyer shall not engage in

conduct that adversely reflects on his fitness
to practice law, nor shall he whether in public
or private life, behave in a scandalous manner
to the discredit of the legal profession.
(Emphasis supplied.)

c. Rule 8.01, Code of Professional Responsibility –

 Rule 8.01 - A lawyer shall not, in his
professional dealings, use language which is
abusive, offensive or otherwise improper.
(Emphasis supplied.)

20. Further, violations of the above-mentioned provisions

warrant either the removal or disbarment or suspension of attorneys,
under Section 27, Rule 138 of the Rules of Court, to wit –

xxx
Section 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 the admission to practice, or for a
willful disobedience of any lawful order of a
superior court, or for corruptly or willful appearing
as an attorney for a party to a case without
authority so to do. (Emphasis supplied.)
xxx

Violation of the attorney’s duty to abstain from all

offensive personality

21. With the actions and statements of Mr Gadon, he has

shown that he has not abstained from all offensive personality, but
had in fact exhibited offensive personality before the public, against
Filipino Muslims, and against supporters of Chief Justice Sereno.

22. The respondent cannot find refuge from the exception in

the provision which allows offensive personality only in cases
‘required by the justice of the cause with which he is charged’, as the
respondent has absolutely no personality in the Supreme Court
proceedings in Baguio City.
 23. In fact, he attempted to delude the public and the Court
that he is an Amicus Curiae, by trying to submit a poorly written,
spelling and grammar-challenged Amicus Curiae Comment on the
Quo Warranto proceeding.

24. But the respondent has fooled no one, as he is not an

Amicus Curiae in the Quo Warranto proceedings, due to the fact that
he was never invited to become an amicus curiae by the Court, nor
can he even pretend to be an impartial personality on the matter, nor
can he even present himself as an expert on quo warranto cases.

25. Further, his Comment is not allowed by the Rules of

Court, as he is not even a party to the Quo Warranto proceedings.

26. This kind of ignorance of the law, rules and even

elementary grammar and spelling has clearly no place in the legal
profession.

27. To recap, this is the absolutely offensive personality

displayed by the respondent, and no clearer proof is these words and
picture –

xxx
MR GADON: Ikaw bobo, putangina mo ka!
Kinanginamo!
xxx
MR GADON: Mga bobo! Mga bobo!
xxx
 xxx
MR GADON: Sampung beses akong luluhod sa
(Moro Islamic Liberation Front para huwag nang
manggulo), iiyak ako ng bato at dugo, kapag
labing-isang pagkakataon at tumanggi pa rin
sila, lulusubin ko sila doon at dadalhin ko ang
buong sandatahang Pilipinas at papatayin ko
silang lahat, susunugin ko ang bahay nila.
Burahin ang lahi nila, kahit masunog ang
kaluluwa ko sa impiyerno gagawin ko 'yan
(Emphasis supplied.)
xxx

Violation of professional responsibility not to engage in conduct

that adversely affects his fitness to practice law

28. Obviously, his conduct in Baguio City, and his remarks

against Muslim Filipinos show conduct which adversely affects his
fitness to practice law, as clearly his statements and actions display a
behavior showing unfitness to bear the serious responsibility of being
a member of the Bar.

29. In full view of the public and the media, the respondent
acted like a madman (apologies to actual madmen) unleashed for a
public spectacle. In fact, reviewing the quality of his unsolicited
pleadings, he appears to be more fit as a third-rate actor (apologies
to actual third-rate actors) than a respectable member of the Bar.
Violation of professional responsibility to not behave in public
life in a scandalous manner to the discredit of the legal
profession

30. With his statements and actions, the respondent has

clearly discredited the legal profession.

31. The following tweets exhibit how low the legal profession
had found itself in due to the respondent’s actions:

a. The legal profession as untrained in spelling –

b. The public ashamed at lawyers in general –

c. Fellow lawyers being ashamed at his hysterics –
d. The respondent turned into a meme –

e. Lawyering described as a foolish profession, among

others –

f. Non-lawyers validating their decision not to pursue law –

g. The respondent as setting the bar too low for the legal
profession –

h. Lawyers judged as also ugly on the inside –

i. The respondent as the new bar for unprofessionalism –

Violation of professional responsibility, in his professional
dealings, not to use language which is abusive, offensive or
otherwise improper.

32. There is no further proof to this violation than to revisit

everything he has said and done in the above-mentioned facts –

Xxx
MR GADON: Ikaw bobo, putangina mo ka!
Kinanginamo!
xxx
MR GADON: Mga bobo! Mga bobo!
xxx
 xxx
MR GADON: Sampung beses akong luluhod sa
(Moro Islamic Liberation Front para huwag nang
manggulo), iiyak ako ng bato at dugo, kapag
labing-isang pagkakataon at tumanggi pa rin
sila, lulusubin ko sila doon at dadalhin ko ang
buong sandatahang Pilipinas at papatayin ko
silang lahat, susunugin ko ang bahay nila.
Burahin ang lahi nila, kahit masunog ang
kaluluwa ko sa impiyerno gagawin ko 'yan
(Emphasis supplied.)
xxx

33. Truly, his words and actions speak for themselves. There
is simply no reason for the respondent to remain as a member of the
legal profession.

34. His continued existence as a member of the legal

profession is literally sickening, and figuratively spits at the sacrifices
our lawyers had made to raise the level of the profession in the
service of those who have nothing in life except a chance at justice.

35. All of these grounds based on the above-mentioned facts

constitute the basis to conclude that respondent Gadon has
committed gross misconduct, gross immoral conduct and violations of
the lawyer’s oath.

36. These actions justify not only mere suspension from the
legal profession, but outright removal from the legal profession.

37. The respondent deserves not a day more in the company

of lawyers in the profession.
 PRAYER

WHEREFORE, premises considered, we most respectfully pray that

the Honorable Commission on Bar Discipline:

a. Give due course to this verified complaint;

b. After notice and hearing, recommend to the Board of Governors
the DISBARMENT OF RESPONDENT LORENZO GADON FOR
GROSS MISCONDUCT, GROSS IMMORAL CONDUCT AND
VIOLATIONS OF THE LAWYER’S OATH.

IN WITNESS WHEREOF, we hereunto set our hands this __ day of

April 2018, at Quezon City

ZENA B. BERNARDO EVANGELINE P. HERNANDEZ

Complainant Complainant

NONA D. ANDAYA-CASTILLO
Complainant

NATIVIDAD DELA CRUZ NATIVIDAD

Complainant

JOSE MARI TOMINES CALLUENG

Complainant

JENNIFER AIZA SANTAOLAYA FAITH ANGELIE CATALAN

Complainant Complainant

MARK VINCENT LIM

Complainant
REPUBLIC OF THE PHILIPPINES )
QUEZON CITY ) S.S.

VERIFICATION

We, ZENA B. BERNARDO, EVANGELINE P. HERNANDEZ,

NONA D. ANDAYA-CASTILLO, NATIVIDAD CRUZ NATIVIDAD,
JOSE MARI TOMINES CALLUENG, JENNIFER AIZA
SANTAOLAYA, FAITH ANGELIE CATALAN, MARK VINCENT LIM,
of legal age, Filipino and with office address at Erythrina Bldg, No. 1
Maaralin cor. Matatag, Barangay Central, Quezon City, after having
been duly sworn to in accordance with law, hereby depose and state:
1. We are the Complainants in the above-captioned case;
2. We caused the preparation and filing of the foregoing Verified
Complaint;
3. We have read the contents of said Verified Complaint and we
attest that the same are true and correct of my own personal
knowledge and based on the records in my possession.

IN WITNESS WHEREOF, we have hereunto set our hands this

__ day of April 2018 in Quezon City.

ZENA V. BERNARDO EVANGELINE P. HERNANDEZ

Complainant Complainant

NONA D. ANDAYA-CASTILLO
Complainant

NATIVIDAD DELA CRUZ NATIVIDAD

Complainant
JOSE MARI TOMINES CALLUENG
Complainant

JENNIFER AIZA SANTAOLAYA FAITH ANGELIE CATALAN

Complainant Complainant

MARK VINCENT LIM

Complainant

SUBSCRIBED AND SWORN to before me this __ day of April

2018 in Quezon City, complainant exhibited to me their government
IDs as indicated above.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2018.