Você está na página 1de 8

1. Lawyer’s Oath.

I, do solemnly swear that I will maintain allegiance to the Republic of the Philippines, I will
support the Constitution and obey the laws as well as the legal orders of the duly constituted
authorities therein; I will do no falsehood, nor consent to the doing of any in court; I will not
wittingly or willingly promote or sue any groundless, false or unlawful suit, or give aid nor
consent to the same; I will delay no man for money or malice, and will conduct myself as a
lawyer according to the best of my knowledge and discretion, with all good fidelity as well to
the courts as to my clients; and I impose upon myself these voluntary obligations without any
mental reservation or purpose of evasion. So help me God.

2. Canon 15: Memorize Rule on Conflict of Interest – Rule 15.01 and Rule 15.03.
 Atty. Jalandoni vs Atty. Villarosa, AC No. 5303, June 15, 2006

Canon 15 of the Code of Professional Responsibility (CPR) highlights the need for candor, fairness and loyalty in all the dealings of lawyers
with their clients. Rule 15.03 of the CPR aptly provides: Rule 15.03—A lawyer shall not represent conflicting interests except by written
consent of all concerned given after a full disclosure of the facts. It is only upon strict compliance with the condition of full disclosure of
facts that a lawyer may appear against his client; otherwise, his representation of conflicting interests is reprehensible. Conflict of interest
may be determined in this manner: There is representation of conflicting interests if the acceptance of the new retainer will require the
attorney to do anything which will injuriously affect his first client in any matter in which he represents him and also whether he will be
called upon in his new relation, to use against his first client any knowledge acquired through their connection.

The rule on conflict of interests covers not only cases in which confidential communications have been confided but also those in which no
confidence has been bestowed or will be used—the rule prohibits a lawyer from representing new clients whose interests oppose those of a
former client in any manner, whether or not they are parties in the same action or in totally unrelated cases.

 Gonzales vs. Atty. Cabucana, AC No. 6836, January 23, 2006

It is well-settled that a lawyer is barred from representing conflicting interests except by written consent of all concerned given after a full
disclosure of the facts. Such prohibition is founded on principles of public policy and good taste as the nature of the lawyer-client relations
is one of trust and confidence of the highest degree. Lawyers are expected not only to keep inviolate the client’s confidence, but also to
avoid the appearance of treachery and double-dealing for only then can litigants be encouraged to entrust their secrets to their lawyers,
which is of paramount importance in the administration of justice. One of the tests of inconsistency of interests is whether the acceptance
of a new relation would prevent the full discharge of the lawyer’s duty of undivided fidelity and loyalty to the client or invite suspicion of
unfaithfulness or double-dealing in the performance of that duty.

The representation of opposing clients, though unrelated, constitutes conflict of interest or, at the very least, invites suspicion of
doubledealing which the Court cannot allow.

While there may be instances where lawyers cannot decline representation, they cannot be made to labor under the conflict of interest
between a present client and a prospective one.—In the same manner, his claim that he could not turn down the spouses as no other
lawyer is willing to take their case cannot prosper as it is settled that while there may be instances where lawyers cannot decline
representation they cannot be made to labor under conflict of interest between a present client and a prospective one. Granting also that
there really was no other lawyer who could handle the spouses’ case other than him, still he should have observed the requirements laid
down by the rules by conferring with the prospective client to ascertain as soon as practicable whether the matter would involve a conflict
with another client then seek the written consent of all concerned after a full disclosure of the facts. These respondent failed to do thus
exposing himself to the charge of double-dealing.

3. Rule on Privileged Communication.


 Ma. Luisa Hadjula vs. Atty. Roceles F. Madianda, AC No. 6711, July 03, 2007
Among the burdens of the relationship is that which enjoins the lawyer to keep inviolate confidential information acquired or revealed
during legal consultations. The fact that one is, at the end of the day, not inclined to handle the client’s case is hardly of consequence. Of
little moment, too is the fact that no formal professional engagement follows the consultation. Nor will it make any difference that no
contract whatsoever was executed by the parties to memorialize the relationship.

The purpose of the rule of confidentiality is to actually to protect the client from possible breach of confidence as a result of a consultation
with a lawyer.

8 GROUNDS OF PRIVILEGED COMMUNICATION

1. Where legal advice of any kind is sought


2. from a professional legal adviser in his capacity as such
3. the communications relating to that purpose
4. made in confidence
5. by the client,
6. are at his instance permanently protected
7. from disclosure by himself or by the legal advisor,
8. except the protection be waived.

4. Memorize Canon 16: Hold in Trust Client’s Moneys and Properties


 Review especially the rule on No Borrowing,Lending (Rule 16.04)
 Barnachea v. Quiocho 339 SCRA 1 (2003)

Money entrusted to a lawyer for a specific purpose such as for the registration of a deed with the Register of Deeds and for expenses and
fees for the transfer for title over real property under the name of his client if not utilized, must be returned immediately to his client upon
demand therefor.—A lawyer is obliged to hold in trust money or property of his client that may come to his possession. He is a trustee to
said funds and property. He is to keep the funds of his client separate and apart from his own and those of others kept by him. Money
entrusted to a lawyer for a specific purpose such as for the registration of a deed with the Register of Deeds and for expenses and fees for
the transfer of title over real property under the name of his client if not utilized, must be returned immediately to his client upon demand
therefor. The lawyer’s failure to return the money of his client upon demand gave rise to a presumption that he has misappropriated said
money in violation of the trust reposed on him. The conversion by a lawyer funds entrusted to him by his client is a gross violation of
professional ethics and a betrayal of public confidence in the legal profession.

 Rubias v. Batiller 51 SCRA 120 (1973)

Prohibition against purchase by lawyer of property in litigation from his client; Article 1491, paragraph (5) of the Philippine Civil Code
construed.—Article 1491 of the Civil Code of the Philippines (like Article 1459 of the Spanish Civil Code) prohibits in its six paragraphs
certain persons, by reason of the relation of trust or their peculiar control either directly or indirectly and "even at a public or judicial
auction," as follows: (1) guardians; (2) agents; (3) administrators; (4) public officers and employees; (5) judicial officers and employees,
prosecuting attorneys, and lawyers; and (6) others specially disqualified by law.

The permanent disqualification of public and judicial officers and lawyers grounded on public policy differs from the first three cases of
guardians, agents and administrators (Article 1491, Civil Code), as to whose transactions, its has been opined, may be "ratified" by means
of and "in the form of a new contract, in which case its validity shall be determined only by the circumstances at the time of execution of
such new contract. The causes of nullity which have ceased to exist cannot impair the validity of the new contract. Thus, the object which
was illegal at the time of the first contract, may have already become lawful at the time of ratification or second contract; or the service
which was impossible may have become possible; or the intention which could not be ascertained may have been clarified by the parties.
The ratification or second contract would then be valid from its execution; however, it does not retroact to the date of the first contract.

5. Read In re: Suspension of Atty. Maquera from the Practice of Law BM 793 July 30, 2004

The Superior Court of Guam hinted that Maquera’s acquisition of Castro’s right of redemption, his subsequent exercise of said right, and
his act of selling the redeemed property for huge profits were tainted with deceit and bad faith when it concluded that Maquera charged
Castro an exorbitant fee for his legal services. The court held that since the assignment of the right of redemption to Maquera was in
payment for his legal services, and since the property redeemed by him had a market value of US$248,220.00 as of December 21, 1987
(the date when the right of redemption was assigned to him), he is liable for misconduct for accepting payment for his legal services way
beyond his actual fees which amounted only to US$45,000.00.

6. Memorize Canon 18 on Competence and Diligence and Rule on Adequate Preparation (Rule 18.02)
 Fernandez v. Atty. Novero
A counsel must constantly keep in mind that his actions or omissions, even malfeasance or nonfeasance, would be binding on his client.
Verily, a lawyer owes to the client the exercise of utmost prudence and capability in that representation. Lawyers are expected to be
acquainted with the rudiments of law and legal procedure, and anyone who deals with them has the right to expect not just a good
amount of professional learning and competence but also a whole-hearted fealty to the client’s cause.

Respondent should bear in mind that while a lawyer owes utmost zeal and devotion to the interest of his client, he also has the
responsibility of employing only fair and honest means to attain the lawful objectives of his client and he should not allow the latter to
dictate the procedure in handling the case.

A lawyer owes entire devotion in protecting the interest of his client, warmth and zeal in the defense of his rights. He must use all his
learning and ability to the end that nothing can be taken or withheld from his client except in accordance with the law. He must present
every remedy or defense within the authority of the law in support of his client’s cause, regardless of his own personal views. In the full
discharge of his duties to his client, the lawyer should not be afraid of the possibility that he may displease the judge or the general public.

7. Rule on Informing Client on Status of Case (Rule 18.04)


 Ruiz vs Santos

It is settled that clients are bound by the mistakes, negligence and omission of their counsel.—The failure of petitioners’ counsel to perfect
the appeal binds petitioners. It is settled that clients are bound by the mistakes, negligence and omission of their counsel. While,
exceptionally, the client may be excused from the failure of counsel, the factual circumstances in the present case do not give us sufficient
reason to suspend the rules of the most mandatory character. Petitioners themselves may not be said to be entirely faultless.

No prudent party would leave the fate of his case completely to his lawyer—it is the duty of the client to be in touch with his counsel so as to
be constantly posted about the case.

 Somosot vs Lara

A client must never be left in the dark even if he has not paid counsel’s billing.—The interrogatories/admission issue happened in August
2001, which tells us that the respondent at about that time was already very sensitive about his billing issue against his client as he had not
been paid from May to August 2001. Assuming the non-payment to be true, such failure should not be a reason not to inform the client of
an important development, or worse, to withhold vital information from her. As the court held in Luisito Balatbat v. Atty. Edgardo Arias,
521 SCRA 1 (2007), a client must never be left in the dark for to do so would destroy the trust, faith and confidence reposed in the retained
lawyer in particular and the legal profession in general.

Lawyer cannot be disbarred if his client is guilty of contributory faults.—In these lights, we hold that while the respondent is liable for a
clear case of misconduct that seriously affects his standing and character as an officer of the Court and as a member of the Bar, this liability
ought to be tempered by the mitigating circumstances we pointed out above. We therefore cannot impose disbarment as penalty. Given
the mitigating circumstances and the extent of their effects on the respondent’s culpability, we hold that a three-month suspension from
the practice of law is the penalty that is more in keeping with the damage the complainant suffered and the interests that the public, the
bar and the administration of justice have to protect.

8. Memorize Canon 21: Preserve Client’s Confidence when Revelations of Confidence and Secrets Allowed

CANON 21 - A LAWYER SHALL PRESERVE THE CONFIDENCE AND SECRETS OF HIS CLIENT EVEN AFTER THE ATTORNEY-CLIENT RELATION IS
TERMINATED.

Rule 21.01 - A lawyer shall not reveal the confidences or secrets of his client except;

(a) When authorized by the client after acquainting him of the consequences of the disclosure;
(b) When required by law;
(c) When necessary to collect his fees or to defend himself, his employees or associates or by judicial action.

9. Canon 22: Withdrawal of Services For Good Cause


a. Memorize Good causes for Withdrawal of Services (Rule 22.01)

Rule 22.01 - A lawyer may withdraw his services in any of the following case:

(a) When the client pursues an illegal or immoral course of conduct in connection with the matter he is handling;
(b) When the client insists that the lawyer pursue conduct violative of these canons and rules;
(c) When his inability to work with co-counsel will not promote the best interest of the client;
(d) When the mental or physical condition of the lawyer renders it difficult for him to carry out the employment effectively;
(e) When the client deliberately fails to pay the fees for the services or fails to comply with the retainer agreement;
(f) When the lawyer is elected or appointed to public office; and
(g) Other similar cases.

b. Duties of Lawyer Who Withdraws (Rule 22.02)

Rule 22.02 - A lawyer who withdraws or is discharged shall, subject to a retainer lien, immediately turn over all papers and property to
which the client is entitled, and shall cooperative with his successor in the orderly transfer of the matter, including all information
necessary for the proper handling of the matter.

10. Canon 22: A lawyer shall withdraw his services only for good cause and upon notice appropriate in the circumstances.
 Enumerate the circumstances where the lawyer may withdraw his services
11. Rule 21.01: A lawyer shall not reveal the confidences or secrets of his client except--- Enumerate
12. Rule 20.01: A lawyer shall be guided by the following factors in determining his fees --- Enumerate

Rule 20.01 - A lawyer shall be guided by the following factors in determining his fees:
(a) the time spent and the extent of the service rendered or required;
(b) the novelty and difficulty of the questions involved;
(c) The importance of the subject matter;
(d) The skill demanded;
(e) The probability of losing other employment as a result of acceptance of the proffered case;
(f) The customary charges for similar services and the schedule of fees of the IBP chapter to which he belongs;
(g) The amount involved in the controversy and the benefits resulting to the client from the service;
(h) The contingency or certainty of compensation;
(i) The character of the employment, whether occasional or established; and
(j) The professional standing of the lawyer.

13. Rule 9.02 – A lawyer shall not divide or stipulate or stipulate to divide a fee for legal service with persons not licensed to
practice law, except --- Enumerate

Rule 9.02 - A lawyer shall not divide or stipulate to divide a fee for legal services with persons not licensed to practice law, except:

(a) Where there is a pre-existing agreement with a partner or associate that, upon the latter's death, money shall be paid over a
reasonable period of time to his estate or to persons specified in the agreement; or
(b) Where a lawyer undertakes to complete unfinished legal business of a deceased lawyer; or
(c) Where a lawyer or law firm includes non-lawyer employees in a retirement plan even if the plan is based in whole or in part, on a
profit sharing agreement.

14. Rules on Suspension and Disbarment:


a. Enumerate the Nature of Bar Discipline Proceedings

BAR DISCIPLINE PROCEEDINGS – Nature

1. Private and confidential


2. Sui Generis
3. Summary in nature
4. Imprescriptible

b. Study Jurisdiction of the CBD in Bar Discipline


JURISDICTION OF THE CBD IN BAR DISCIPLINE

A. In General
Pursuant to Rule 139 – B, the IBP BoG was empowered to police its own ranks, investigate and penalize erring members of the
Bar either in government and /or private service except judges and justices.

The SC exercises exclusive jurisdiction to regulate the practice of law. It exercises such disciplinary functions through the IBP,
but it does not relinquish its duty to form its own judgment. Disbarment proceedings are exercised under the sole jurisdiction of
the SC, and the IBP’s recommendations imposing the penalty of suspension from the practice of law or disbarment are always
subject to this Court’s review and approval. (Ylaya v. Gacott)
B. Special Rule for Judges and Justices; Government Lawyers
Pursuant to Bar Matter 1645 (RE: Amendment of Rule 139-B), all complaints for disbarment, suspension and discipline filed
against incumbent Justices of the CA, Sandiganbayan, CTA, judges of lower courts, and lawyers in government service, whether
or not they are charged singly or jointly with other respondents, and whether or not such complaint deals with acts unrelated to
the discharge of their official functions, shall be forwarded by the IBP to the SC for appropriate action.

c. Rule on Quantum of Proof

RULE ON QUANTUM OF PROOF

In SUSPENSION or DISBARMENT proceedings, lawyers enjoy the presumption of innocence, and the burden of proof rests upon the
complainant to clearly prove his or her allegations by preponderant evidence. In the absence of preponderant evidence, the presumption
of innocence of the lawyer continues and the complaint against him must be dismissed. (Rodica v. Lazaro, et. al.)

Preponderance of Evidence – the evidence adduced by one side is, as a whole, superior to or has greater weight than that of the other. It
means evidence which is more convincing to the court as worthy of belief than that which is offered in opposition thereto.

d. Enumerate the Kinds of Sanctions

KINDS OF SANCTIONS

1. Disbarment
2. Suspension
3. Interim Suspension
4. Reprimand
5. Admonition
6. Probation
7. Other sanctions and remedies
a. Restitution
b. Assessment of costs
c. Limitation upon practice
d. Warning
e. Taking of professional responsibility examinations or MCLEs

e. Rule on Prescription.

Atty. Rinen did not deny his failure to personally verify the identity of all parties who
Talisic v. Atty Rinen
purportedly signed the subject document and whom, as he claimed, appeared before him on April 7,
1994. Such failure was further shown by the fact that the pertinent details of the community tax
certificates of Wilberto and his sister, as proof of their identity, remained unspecified in the subject
deed’s acknowledgment portion. Clearly, there was a failure on the part of Atty. Rinen to exercise the
due diligence that was required of him as a notary public ex-officio. The lapses he committed in relation
to such function then justified the recommendations presented by the IBP. (20 years, revoked his
notarial commission and warned)
Ang v. Atty. Gupana
Where the notary public is a lawyer, a graver responsibility is placed upon his shoulder by reason of his solemn
oath to obey the laws and to do no falsehood or consent to the doing of any.(april 29, 1994 to Feb. 5 2014; 20
years; Suspended and revoked his notarial commission)
Dizon v. Atty. Cabucana

As a notary public, Atty. Cabucana should not notarize a document unless the person who signs it is the
same person executing it and personally appearing before him to attest to the truth of its contents. This
is to enable him to verify the genuineness of the signature of the acknowledging party and to ascertain
that the document is the party's free and voluntary act and deed.(suspended for 2 months and his
notarial commission revoked. Nov.6 2003 to march 12 2014)

f. Rule that even the lapse of considerable time from the commission of the offending act to the
institution of the administrative complaint will not erase the administrative culpability of a lawyer…
 Heck v. Santos

Note that the CBD Rules of Procedure used to contain a provision ( Rule VIII, Section 1) for a
prescriptive period for the filing of administrative complaints which was within two years from
discovery.

The SC in Frias v. Bautista – Lozada, struck down the provision as void and of no legal effect for
being ultra vires.
15. Grounds:
 Violations of duties owed to the clients
a. Failure to preserve the client’s property
b. Failure to preserve the client’s confidence
c. Failure to avoid conflicts of interest
d. Lack of diligence
e. Lack of competence
f. Lack of candor
 Violation of duties owed to the public
a. Failure to maintain personal integrity
b. Failure to maintain the public trust
 Violations of duties owed to the legal system
a. False statements, fraud and misrepresentation
b. Abuse of legal process
c. Improper communications with individuals in the legal system
 Violations owed to the profession
a. Prior discipline orders
16. Rule that the SC exercises exclusive jurisdiction to regulate the practice of law
 Ylaya v. Gacott
The SC exercises exclusive jurisdiction to regulate the practice of law. It exercises such disciplinary functions through the IBP, but it does
not relinquish its duty to form its own judgment. Disbarment proceedings are exercised under the sole jurisdiction of the SC, and the IBP’s
recommendations imposing the penalty of suspension from the practice of law or disbarment are always subject to this Court’s review and
approval. (Ylaya v. Gacott)

17. Special Rule for Judges and Justices; Government Lawyers

Special Rule for Judges and Justices; Government Lawyers


Pursuant to Bar Matter 1645 (RE: Amendment of Rule 139-B), all complaints for disbarment, suspension and discipline filed against
incumbent Justices of the CA, Sandiganbayan, CTA, judges of lower courts, and lawyers in government service, whether or not they are
charged singly or jointly with other respondents, and whether or not such complaint deals with acts unrelated to the discharge of their
official functions, shall be forwarded by the IBP to the SC for appropriate action.

18. Note that a lawyer can even be disciplined or disbarred for immoral conduct made prior to his or her admission to the Bar
 Virtusio v. Virtusio

Lawyers, as officers of the court and instruments for the administration of justice, are expected to maintain not only legal proficiency but
also a high standard of morality, honesty, and fair dealing. Since good moral character is an essential qualification for the admission to the
practice of law, maintaining such trait is a condition for keeping the privilege.

19. Read the case of Garrido v. Garrido, involving the disbarment case on the ground of immorality, the defense of the lawyer
was that the alleged immoral conduct of entering into sexual relations with a man whom she knew was married was
committed while she was NOT YET a lawyer.

The SC held that this defense will not exempt the respondent from sanctions since good moral character is required as a condition
precedent to admission to the Bar. The SC held that “membership in the Bar is a privilege burdened with conditions. As a privilege
bestowed by law through the SC, membership in the Bar can be withdrawn where circumstances concretely show the lawyer’s lack of the
essential qualifications required of lawyers.”

20. Read also the case of Macarubbo v. Macarubbo and memorize the grounds for reinstatement.

GROUNDS FOR REINSTATEMENT


1. There must be proof of remorse and reformation.
2. Sufficient time must have lapsed from the imposition of the penalty to ensure a period of reform.
3. The age of the person asking for clemency must show that he still has productive years ahead of him that can be put to good
use by giving him a chance to redeem himself.
4. There must be a showing of promise (such as intellectual aptitude, learning or legal acumen or contribution to legal scholarship
and the development of the legal system or administrative and other relevant skills), as well as potential for public service.
5. There must be other relevant factors and circumstances that may justify clemency.

Moreover, to be reinstated to the practice of law, the applicant must, like any other candidate for admission to the bar, satisfy the Court
that he is a person of good moral character.

21. Judicial Conduct


a. Memorize CANON 1 on INDEPENDENCE and Not to Allow Social Relations to Influence Judgment

CANON 1- A judge should uphold the integrity and independence of the judiciary
Rule 1.01 – A judge should be the embodiment of competence, integrity, and independence.
Rule 1.02 – A judge should administer justice impartially and without delay.
Rule 1.03 – A judge should be vigilant against any attempt to subvert the independence of the judiciary and resist any pressure from
whatever source.
 Romero v. Valle

It is the duty of both counsel and judge to maintain, not to destroy, the high esteem and regard for courts. Any act on the part of one or
the other that tends to undermine the people’s respect for, and confidence in, the administration of justice, is to be avoided. And this,
even if both have to restrain pride from taking the better part of their system. To be expected then of petitioner and respondent is a sense
of shared responsibility, a crucial factor in the administration of justice.

The relations between counsel and judge should be based on mutual respect and on a deep appreciation by one of the duties of another.
Thus, counsel is expected to observe and maintain the respect due to the courts of justice and judicial officers. Although allowed some
latitude of remarks or comment in the furtherance of causes, he upholds, his arguments, written or oral, should be gracious to both court
and opposing counsel and be of such words as may properly be addressed by one gentleman to another. Certainly and most especially in
our culture, raising one’s voice is a sign of disrespect, improper to one whose “investiture into the legal profession places upon his
shoulders no burden more basic, more exacting and more imperative than that of respectful behavior towards the courts.

b. Memorize CANON 4 on Avoidance of Impropriety

CANON 4 – A judge may, with due regard to official duties, engage in activities to improve the law, the legal system and the
administration of justice.
Rule 4.01 – A judge may, to the extent that the following activities do not impair the performance of judicial duties or case doubt on the
judge’s impartiality:
a. speak, write, lecture, teach or participate in activities concerning the law, the legal system and the administration of justice;
b. appear at a public hearing before a legislative or executive body on matters concerning the law, the legal system or the
administration of justice and otherwise consult with them on matters concerning the administration of justice;
c. serve on any organization devoted to the improvement of the law, the legal system or the administration of justice.

 Talens v. Arceo

The integrity of the Judiciary rests not only upon the fact that it is able to administer justice but also upon the perception and confidence of
the community that the people who run the system have done justice. At times, the strict manner by which we apply the law may, in fact,
do justice but may not necessarily create confidence among the people that justice, indeed, is served. Hence, in order to create such
confidence, the people who run the judiciary, particularly judges and justices, must not only be proficient in both the substantive and
procedural aspects of the law, but more importantly, they must possess the highest integrity, probity, and unquestionable moral
uprightness, both in their public and private lives. Only then can the people be reassured that the wheels of justice in this country run with
fairness and equity, thus creating confidence in the judicial system.

c. Rule on Dignity (Liwanag v. Lustre) and Relations with Lawyers (People v. Maceda)
 Liwanag v. Lustre

The Court cannot countenance any act or omission, on the part of the officials at every level in the administration of justice, which erodes
rather than enhances the public’s faith and trust in the judiciary. Respondent’s disgraceful conduct surely merits sanctions even if he has
already retired as of November 1, 1998. For the serious misconduct of respondent, the penalty provided for in Rule 140, Section 10, of the
Rules of Court, by way of fine in the maximum amount should be imposed.

 People v. Maceda

Contempt of court presupposes a contumacious attitude, a flouting or arrogant belligerence, a defiance of the court. And, while courts are
inherently empowered to punish for contempt to the end that they may enforce their authority. preserve their integrity, maintain their
dignity, and insure the effectiveness of the administration of justice, nevertheless, such power should be exercised on the preservative and
not on the vindictive principle, for the power to punish for contempt, being drastic and extraordinary in its nature, should not be resorted
to unless necessary in the interest of justice
Ganto sana atta definition nung relation with lawyers kaso wala sa case ngy or maling case lng nbasa q, They can't take part in a case where
any family member of theirs is a lawyer of a party or is associated in any way to the case. They can't use or lend the prestige of their office
for their own private interests as well as those of their families or of anyone else.

Você também pode gostar