Digests

Atty. Magdamo represented the sisters of the deceased Fe Gonzalo-Buenviaje in a bigamy case against Lito Buenviaje, who claimed to be Fe's surviving spouse and the joint account holder in a bank where Fe had deposited her lifetime savings accumulated from working as a nurse in Switzerland. Following Fe's death, Atty. Magdamo sent a formal notice to the bank regarding the death of the depositor, which contained inflammatory characterizations of Buenviaje and factual assertions regarding his marital status and criminal liability that had not been adjudicated by any court.

A lawyer violates the Code of Professional Responsibility when, in the course of representing a client, he employs disrespectful, intemperate, and malicious language against an opposing party and asserts as fact allegations that have not been judicially proven; such conduct erodes public respect for the legal profession and warrants disciplinary sanction regardless of the lawyer's zeal for his client's cause.

E-PCIBank entered into a Contract for Services with HI, a company providing janitorial and messengerial services, which was renewed annually until 2001. When the contract finally expired, the bank bidded out its requirements to other agencies, leading to the pull-out of the petitioners from the bank's premises and their subsequent filing of illegal dismissal complaints.

Helpmate, Inc. is a legitimate independent job contractor because it possesses substantial capital and carries on a distinct business, meaning no employer-employee relationship exists between the principal bank and the contractor's employees; furthermore, the NLRC may validly consider evidence submitted for the first time on appeal to ascertain factual truths in labor cases.

Ong Chia arrived in the Philippines from China in 1932 at the age of nine and lived there for over five decades, establishing a business and a family. In 1989, he filed a petition for naturalization under C.A. No. 473, asserting he possessed all qualifications and no disqualifications. While the trial court was initially satisfied with his testimony and knowledge of Philippine history, the State later discovered discrepancies between his current petition and a previous 1977 administrative application for naturalization.

The rule on the formal offer of evidence under Rule 132, Section 34 of the Rules of Court does not strictly apply to naturalization proceedings; pursuant to Rule 143 (now Rule 1, Section 4), the Rules of Court apply only by analogy or in a suppletory character in such cases, allowing the appellate court to consider documents presented by the State for the first time on appeal to ensure the applicant's full qualification for citizenship.