MANILA — The Supreme Court (SC) has suspended, for the second time, former press secretary Rose Beatriz “Trixie” Cruz-Angeles over the use of “grossly abusive and offensive” language in a pleading submitted to a court.

In a resolution dated March 27, 2023 but released only recently, the SC Third Division suspended Cruz-Angeles from the practice of law for six months and her co-counsel Ahmed Paglinawan was reprimanded for violation of the Code of Professional Responsibility, which until recently, governed the conduct of Philippine lawyers.

Rule 8.01 of the code prohibits the use of abusive, offensive or otherwise improper language.

The complaint was filed by lawyer Roderick Manzano in May 2016 because of statements made by Cruz-Angeles and Paglinawan in a pleading they filed in an unlawful detainer case at the Metropolitan Trial Court of Quezon City.

The two had called the plaintiff in the case an “incorrigible liar,” an “INC (Iglesia ni Cristo) patsy,” “Eduardo Manalo’s pawn,” among other terms.

Both the Integrated Bar of the Philippines’ Commission on Integrity and Bar Discipline and the IBP Board of Governors both recommended Cruz-Angeles’ suspension for 6 months due to her prior suspension while Paglinawan’s penalty was reduced to reprimand since it was his first offense.

The Supreme Court adopted the recommendation after finding that the two never disputed that they made the statements, which for the court, were “grossly abusive and offensive, which are not befitting the dignity of the legal profession.”

And while the statements were made in a judicial proceeding, the high court did not consider them privileged communication exempt from liability because they were deemed “irrelevant” to the unlawful detainer case.

“[T]hese statements were made for the purpose of insulting, dishonoring, and humiliating the complainants in the unlawful detainer case. As such, the subject statements are outside the purview of privileged communication,” SC said.

The high court did not consider significant that Manzano, the complainant, did not suffer any injury or did not have any interest in the disciplinary proceeding, since it is an investigation into the conduct of one of its officers, and “prosecuted solely for the public welfare.”

Cruz-Angeles had previously been suspended in 2016 for 3 years, also for violating the Code of Professional Responsibility, when she failed to attend to an annulment case despite acceptance of legal fees.

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Cruz-Angeles would later work for President Ferdinand Marcos, Jr. as press secretary from June 30, 2022 to October 4, 2022.

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