K. L. Delgado - Law Office & Notary Public

𝐏𝐑𝐎𝐂𝐋𝐀𝐌𝐀𝐓𝐈𝐎𝐍 𝐍𝐎. 𝟏𝟐𝟔𝟒, 𝐬. 𝟐𝟎𝟐𝟔

Declaring Wednesday, 27 May 2026, a Regular Holiday Throughout the Country, in observance of Eid'l Adha (Feast of Sacrifice)

Visit the Official Gazette website: https://www.officialgazette.gov.ph/RJdUhv

The has disbarred a lawyer for using a false Mandatory Continuing Legal Education (MCLE) compliance number in his pleadings.

In a 𝘗𝘦𝘳 𝘊𝘶𝘳𝘪𝘢𝘮 Decision, the SC 𝘌𝘯 𝘉𝘢𝘯𝘤 disbarred Atty. Jose R. Hidalgo (Atty. Hidalgo) for dishonest conduct in violation of the 𝘊𝘰𝘥𝘦 𝘰𝘧 𝘗𝘳𝘰𝘧𝘦𝘴𝘴𝘪𝘰𝘯𝘢𝘭 𝘙𝘦𝘴𝘱𝘰𝘯𝘴𝘪𝘣𝘪𝘭𝘪𝘵𝘺 𝘢𝘯𝘥 𝘈𝘤𝘤𝘰𝘶𝘯𝘵𝘢𝘣𝘪𝘭𝘪𝘵𝘺 (𝘊𝘗𝘙𝘈).

Atty. Hidalgo represented the defendant in a malicious prosecution case pending before Branch 153, Regional Trial Court, Biñan City. In the answer he filed for his client, Atty. Hidalgo included his MCLE compliance number, which is required for lawyers.

The plaintiff's lawyer filed a motion to expunge Atty. Hidalgo's answer from the records, claiming that he did not actually comply with the MCLE requirements. Attached to the motion was a Certification from the MCLE Office stating that Atty. Hidalgo had not complied from the first compliance period up to the present.

In ordering the disbarment of Atty. Hidalgo, the SC emphasized that Canon II of the 𝘊𝘗𝘙𝘈 requires lawyers to act with propriety and maintain the appearance of propriety in personal and professional dealings, observe honesty, respect and courtesy, and uphold the dignity of the legal profession consistent with the highest standards of ethical behavior.

Lawyers are also required under Canon III to uphold the Constitution, obey the laws of the land, and promote respect for laws and legal processes.

The SC held that Atty. Hidalgo violated these Canons, stating that his act of indicating false information in the pleadings he filed “constitutes bad faith and dishonesty, and shows blatant disrespect of the courts and its rules.”

The SC also fined Atty. Hidalgo PHP 35,000 for willful disobedience, a less serious offense, for ignoring the IBP's order when he did not submit an answer and a verified position paper.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=164745.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=164728.

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