Statements made by a Senator during a Senate speech, even if offensive and violative of a lawyer's ethical duties towards the courts, are covered by parliamentary immunity under Article VI, Section 11 of the Constitution and cannot be the basis for disciplinary action by the Court, although such immunity is intended for the benefit of the legislative institution and the people, not for personal attacks.

The case arose following Senator Miriam Defensor-Santiago's privilege speech on the Senate floor where she expressed extreme frustration and used insulting language directed at the Supreme Court and its members, particularly then Chief Justice Artemio Panganiban, after the Judicial and Bar Council (JBC) effectively excluded non-incumbent justices, like herself, from nomination for the position of Chief Justice.

• Complainant Antero J. Pobre submitted a sworn letter/complaint regarding excerpts from a speech delivered by Senator Miriam Defensor-Santiago on the Senate floor.
• In the speech, Senator Santiago stated, among other things: "I spit on the face of Chief Justice Artemio Panganiban and his cohorts in the Supreme Court, I am no longer interested in the position [of Chief Justice] if I was to be surrounded by idiots. I would rather be in another environment but not in the Supreme Court of idiots x x x."
• Senator Santiago admitted making the statements but claimed they were part of a privilege speech related to perceived anomalies in the Judicial and Bar Council's (JBC) nomination process for Chief Justice, specifically the exclusion of non-sitting justices like herself.
• The speech was prompted by Senator Santiago's dissatisfaction with the JBC's decision to consider only incumbent Supreme Court justices for the Chief Justice position after initially inviting public applications.
• Pobre considered these statements a display of total disrespect towards the Chief Justice and the Court, constituting direct contempt, and sought disciplinary action against Senator Santiago as a lawyer.

• Antero J. Pobre argued that Senator Santiago's statements showed total disrespect towards the Chief Justice and members of the Supreme Court.
• Pobre contended that the remarks constituted direct contempt of court.
• Pobre requested that disbarment proceedings or other disciplinary actions be initiated against Senator Santiago for her conduct.

• Senator Miriam Defensor-Santiago did not deny making the statements but argued they were covered by parliamentary immunity under Article VI, Section 11 of the Constitution.
• She claimed the statements were part of a speech delivered in the discharge of her duties as a Senator, aimed at exposing perceived anomalies in the JBC nomination process for Chief Justice with a view to potential remedial legislation.
• She asserted that her intent was to critique an "unjust act" by the JBC, not merely to express personal anger, although the Court noted the language seemed rooted in personal frustration.
• She questioned the complainant's motives and argued Pobre failed to prove she actually made the statements, despite her implicit admission by invoking privilege.

• Does the constitutional provision on parliamentary immunity shield Senator Miriam Defensor-Santiago, a lawyer, from disciplinary action by the Supreme Court for offensive and disrespectful statements made against the Court and its members during a Senate speech?
• Did Senator Santiago's statements, despite the claim of parliamentary immunity, violate her duties as a lawyer under the Code of Professional Responsibility?

• Yes, the Court ruled that Senator Santiago's statements, delivered during a Senate speech, fall under the absolute protection of parliamentary immunity granted by Article VI, Section 11 of the Constitution, which prevents questioning her in any other place, including the Court, for speech or debate in Congress.
• The Court held that while the language used was highly improper, offensive, and disrespectful, tending to denigrate the judiciary and clearly violating Canons 8 and 11 of the Code of Professional Responsibility regarding respectful conduct towards courts, the constitutional immunity prevails over the Court's power to discipline lawyers for such conduct when it occurs within a privileged legislative speech.
• Despite dismissing the complaint due to immunity, the Court strongly admonished Senator Santiago, reminding her of her ethical duties as a member of the Bar to maintain respect for the courts and emphasizing that parliamentary immunity is not a personal privilege to abuse but a protection for the legislative function. The Court also noted the Senate's failure to take disciplinary action under its own rules against unparliamentary language.

• Parliamentary Immunity (Speech or Debate Clause): Defined under Article VI, Section 11 of the Constitution, this doctrine grants Senators and Members of the House immunity from being questioned or held liable in any other forum for any speech or debate delivered in Congress or its committees. In this case, it was invoked by Senator Santiago and upheld by the Court as the basis for dismissing the disciplinary complaint, shielding her statements made on the Senate floor from judicial sanction, despite their offensive content.
• Supreme Court's Power to Discipline Lawyers: Defined under Article VIII, Section 5(5) of the Constitution, this doctrine establishes the Supreme Court's authority to promulgate rules concerning the admission to the practice of law, the Integrated Bar, and to discipline lawyers. The Court acknowledged this power but deemed it subordinate to the specific constitutional grant of parliamentary immunity in this instance, although it affirmed that lawyers, even those in public office, remain subject to the Code of Professional Responsibility for conduct demonstrating unfitness, including disrespect towards courts, unless protected by a specific immunity like the speech or debate clause.
• Lawyer's Duty of Respect Towards Courts: Embodied in Canon 8 (Rule 8.01) and Canon 11 of the Code of Professional Responsibility, this principle requires lawyers to use respectful language in their professional dealings and to observe and maintain respect due to the courts and judicial officers. The Court found Senator Santiago clearly violated this duty with her insulting remarks but could not impose discipline due to parliamentary immunity. The Court reiterated this duty applies to all lawyers, including those in high public office.

• "x x x I am not angry. I am irate. I am foaming in the mouth. I am homicidal. I am suicidal. I am humiliated, debased, degraded... I spit on the face of Chief Justice Artemio Panganiban and his cohorts in the Supreme Court, I am no longer interested in the position [of Chief Justice] if I was to be surrounded by idiots. I would rather be in another environment but not in the Supreme Court of idiots x x x."
• "No lawyer who has taken an oath to maintain the respect due to the courts should be allowed to erode the people's faith in the judiciary."
• "Authorities are agreed that parliamentary immunity is not an individual privilege accorded the individual members of the Parliament or Congress for their personal benefit, but rather a privilege for the benefit of the people and the institution that represents them."
• "The parliamentary non-accountability thus granted to members of Congress is not to protect them against prosecutions for their own benefit, but to enable them, as the people's representatives, to perform the functions of their office without fear of being made responsible before the courts or other forums outside the congressional hall."

• Osmeña, Jr. v. Pendatun (109 Phil. 863): Cited to explain the nature and purpose of parliamentary immunity as a fundamental privilege necessary for legislative function, not personal benefit.
• Tenney v. Brandhove (34 US 367): Referenced American jurisprudence on legislative privilege, indicating its foundation in long experience and necessity for the legislative process.
• In Re: Vicente Sotto (82 Phil. 595): Cited to emphasize the danger of eroding public confidence in the judiciary and as a precedent where the Court disciplined a lawyer (also a legislator, though the offensive act was publication outside Congress) for disrespecting the Court. The Court noted Santiago should have taken its message to heart.
• Ali v. Bubong (A.C. No. 4018): Cited for the principle that lawyers in public service bear a higher degree of social responsibility.
• In re Integration of the Bar of the Philippines (49 SCRA 22): Referenced regarding the Court's power over the Integrated Bar, including enforcing ethical standards and shielding the judiciary.
• In Re: Letter Dated 21 February 2005 of Atty. Noel S. Sorreda (A.M. No. 05-3-04-SC): Cited where the Court reiterated the duty of attorneys to show respect to the judicial office.
• Rheem of the Philippines v. Ferrer (20 SCRA 441): Cited for the first canon of legal ethics demanding lawyers maintain a respectful attitude towards courts for the maintenance of the court's supreme importance.
• Surigao Mineral Reservation Board v. Cloribel (31 SCRA 1): Revisited in Sorreda, cited for the principle that a lawyer is an officer of the court whose duty is to uphold its dignity and authority, not promote distrust.
• Vitriolo v. Dasig (A.C. No. 4984): Cited for the rule that a lawyer in government may be disciplined as a Bar member if misconduct in office also violates the lawyer's oath.
• Gacias v. Balauitan (A.C. No. 7280): Cited for the principle that lawyers can be disciplined for misconduct in their private capacity if it reflects a want of probity or good demeanor, showing unfitness for the legal profession.
• Tacordan v. Ang (G.R. No. 159286): Mentioned as another instance where the Court disciplined a lawyer for insolent behavior towards the Court.
• Tiongco v. Savillo (A.M. No. RTJ-02-1719): Cited to underscore the duty of respect lawyers owe to the courts.

• Constitution, Article VI, Section 11: The core provision granting parliamentary immunity ("Speech or Debate Clause") invoked by the respondent and applied by the Court.
• Constitution, Article VIII, Section 5(5): The provision granting the Supreme Court power over the practice of law and the Integrated Bar, including lawyer discipline.
• Constitution, Article VIII, Section 8: Mentioned regarding the composition of the JBC, noting the Chief Justice sits as ex-officio chairperson.
• Code of Professional Responsibility, Canon 8, Rule 8.01: Prohibits lawyers from using abusive, offensive, or improper language in professional dealings; cited as violated by the respondent's statements.
• Code of Professional Responsibility, Canon 11: Requires lawyers to observe and maintain respect due to courts and judicial officers; cited as violated by the respondent's statements.
• Rules of the Senate, Rule XXXIV, Section 93: Mentioned as the Senate's own rule prohibiting offensive or improper language against another Senator or any public institution.
• Rules of the Senate, Sections 95 & 97: Alluded to regarding the Senate's procedure for handling unparliamentary conduct (calling Senator to order, referral to Ethics Committee), which was apparently not followed in this instance.