FACTS OF THE CASE

The Presidential Commission on Good Government (PCGG), raised a complaint before the Sandiganbayan (SB) against
Eduardo M. Cojuangco, Jr. and Teodoro Regala and his partners in the ACCRA law firm, for the recovery of alleged ill-
gotten wealth, which includes shares of stocks in the named corporations in PCGG Case No. 33 (Civil Case No. 0033),
entitled "Republic of the Philippines versus Eduardo Cojuangco, et al."

In their answer to the Expanded Amended Complaint, ACCRA lawyers requested that PCGG similarly grant the same
treatment to them as accorded Roco. The PCGG has offered to the ACCRA lawyers the same conditions availed of by Roco
but the ACCRA lawyers have refused to disclose the identities of their clients.

ISSUE
Whether or not client’s identity in a case involving and acquiring companies allegedly sourced from ill-gotten wealth is
privileged and disclosure of such is unethical.

RULING
The court held that the client identity in this case is privileged. As a matter of public policy, a client's identity should not
be shrouded in mystery. This general rule is however qualified by some important exceptions:

1) Client identity is privileged where a strong probability exists that revealing the client's name would implicate that
client in the very activity for which he sought the lawyer's advice.
2) Where the government's lawyers have no case against an attorney's client unless, by revealing the client's name, the
said name would furnish the only link that would form the chain of testimony necessary to convict an individual of a
crime.

The circumstances involving the engagement of lawyers in the case at bench, therefore, clearly reveal that the instant
case falls under the first and third exception.

The attorney-client privilege, as currently worded in the Rules of Court provides the disqualification by reason of
privileged communication.