Attempted Assassination of Philippine Lawyer Karen Quinanola-Gonzales
The New York City Bar Association (“City Bar”) condemns the September 1, 2022, attempted assassination of Philippine lawyer Karen Quiñanola-Gonzales.[1]
I. The Attempted Assassination of Quiñanola-Gonzales
On the night of September 1, 2022,[2] Karen Quiñanola-Gonzales, 43, was driving her Honda sedan[3] in Mandaue City, on the border of Barangay Tipolo and Barangay Banilad, en route from her office to her home.[4] Quiñanola-Gonzales is employed as a senior corporate attorney with the Cebu Port Authority, heading up the Port Authority’s Business Marketing & Development Department.[5] Quiñanola-Gonzales’s 19-year-old son, Keith Gonzales, was a passenger in the vehicle.[6]
As Quiñanola-Gonzales was traversing the Panagdait-bound lane of Hernan Cortez Street,[7] two assailants riding in tandem on a motorcycle pulled up alongside her,[8] firing a .45-caliber pistol at least six times into the driver’s side of the vehicle.[9] Quiñanola-Gonzales was hit in the neck and her son was hit in the back.[10] The assailants fled the scene,[11] and Quiñanola-Gonzales and her son were rushed to a local hospital, where Quiñanola-Gonzales underwent surgery.[12] Fortunately, both victims survived the attack.[13]
II. The Response to the Assassination Attempt
The Philippine National Police (“PNP”) and the National Bureau of Investigation (“NBI”) are conducting parallel investigations of the attempted assassination, with the NBI designating the matter a “command” (priority) case.[14] The Region VII office of the national Commission on Human Rights is also probing the attack.[15] Police recently identified a suspected gunman. However, there is at least one accomplice – the motorcycle driver – who remains unidentified.[16]
The shootings of Quiñanola-Gonzales and her son have been widely condemned by the Port Authority,[17] and bar associations and other lawyers’ organizations, as well as civil society generally.
The Free Legal Assistance Group (“FLAG”) was quick to denounce Quiñanola-Gonzales’s attempted murder, emphasizing that it is “the first recorded assault against a lawyer since the new administration [of Ferdinand Marcos, Jr.] took over” on June 30, 2022. FLAG has called on law enforcement authorities to expedite their investigation to arrest the assailants; and, in addition, FLAG is urging Congress to pass legislation protecting lawyers and other human rights defenders. FLAG also asks that the Supreme Court continue its investigation into the killing of lawyers, begun during the Duterte administration. FLAG voiced concerns that “[e]xtrajudicial killings that flourished under the Duterte administration continue unchecked under Marcos Jr.’s rule.”[18]
The Integrated Bar of the Philippines’ (“IBP”) Cebu City chapter has similarly deplored the attempted assassination, highlighting the irony of the fact that the day of the assault – September 1 – was the first day of “Rule of Law Month” in the Philippines. The IBP is offering a substantial reward for information leading to the apprehension and arrest of those responsible for the attack, and has stated that its security committee “will actively take part” in law enforcement’s investigation. The IBP has underscored “the government’s responsibility to guarantee that lawyers can do their job without any threat to their safety and security,” reiterating that “[m]embers of the legal profession must be able to do their duties freely without fear of reprisal or violence.”[19]
The National Union of People’s Lawyers (“NUPL”) has likewise urged authorities to expedite their investigations into the assassination attempt, stating that the assault “underscores the continuing aggression against lawyers and legal professionals.” The NUPL has stated that the situation is aggravated by the Duterte administration’s failure to respond to such threats and attacks and the existing “culture of impunity.” Further, the NUPL has called on the Supreme Court to conduct its own “prompt, effective, thorough, competent and impartial independent investigation” of the attack and to support fact-finding missions of the United Nations and non-governmental organizations.[20]
The Philippines Commission on Human Rights (“CHR”) “vehemently decries this latest attempt against a lawyer and calls for swift action from all concerned authorities to ensure accountability of perpetrators.” The CHR continued: “It cannot be overemphasized that lawyers and judges deserve utmost protection and an enabling environment that will allow them to freely dispense their duties without the perpetual fear that it may lead to harmful and/or violent reprisal.” The CHR has called on law enforcement to hold accountable all of those involved in the crime. And, like FLAG, the CHR has called for Congress’ enactment of legislation to “concretely address the continuing violence against legal professionals and all those working for justice and human rights.”[21]
As the CHR’s reference to “the continuing violence against legal professionals” indicates, the recent attempt on the life of Quiñanola-Gonzales is by no means an isolated instance. The City Bar closely tracked violent attacks on legal professionals throughout the Duterte regime.[22] By one authoritative account, 69 judges, prosecutors, and lawyers were killed during the Duterte years, in addition to 17 paralegals.[23]
III. Protections for Quiñanola-Gonzales Under International Law
International law expressly recognizes the unique role that lawyers play in any society. Because lawyers serve as the guardians of justice for all, international law accords lawyers special protections.[24]
For example, the U.N. Basic Principles on the Role of Lawyers provide that “[l]awyers shall not be identified with their clients or their clients’ causes as a result of discharging their functions.” In other words, clients’ positions and causes are not to be attributed to their counsel.[25] The U.N. Basic Principles further provide that governments are to “ensure that lawyers are able to perform all of their professional functions without intimidation, hindrance, harassment or improper interference.”[26] In addition, “[w]here the security of lawyers is threatened as a result of discharging their functions,” the U.N. Basic Principles state that the lawyers “shall be adequately safeguarded by the authorities.”[27] Quiñanola-Gonzales was entitled to all of these protections.
IV. Resolution and Call to Action
The New York City Bar Association joins the international community in condemning the attempted assassination of Karen Quiñanola-Gonzales and fears that it may be a harbinger of things to come. For years, the Philippines has been – by far – the most dangerous country in the world for legal professionals. The attempted assassination of Quiñanola-Gonzales has now dashed any hope that the new Philippine administration would bring with it an end to the international scandal of dozens of murderous assaults on judges, prosecutors, lawyers, and paralegals throughout the country.[28]
The City Bar calls on the new Philippine administration to bring to justice all responsible for the assault on Quiñanola-Gonzales and her son, and, going forward, to take all measures necessary to ensure that legal professionals are able to fulfill their professional obligations safely and without impediment. Further, the new administration must move swiftly to investigate and prosecute attacks on legal professionals under the prior administration. The long-prevailing culture of impunity must end.
The City Bar stands steadfast in solidarity with judges, prosecutors, lawyers, and other legal professionals in the Philippines and elsewhere around the globe, and wholeheartedly supports their vital work seeking a better, more just, and more peaceful world for all.
Footnotes
[1] More than 150 years old, the New York City Bar is an organization of over 23,000 members in New York City and elsewhere throughout the United States, and in more than 50 countries around the globe. Its members include judges, prosecutors, defense counsel, government lawyers, and public interest/non-governmental organization practitioners, as well as legal academics and attorneys representing nearly every major law firm and corporation in the United States. The City Bar has a long and distinguished history of promoting the rule of law and human rights, including the rights of legal professionals to fulfill their professional obligations. The City Bar’s Task Force on the Independence of Lawyers and Judges assisted with this Statement.
[2] Some sources report that the assault occurred at approximately 9:00 p.m., while others put the time closer to 10:00 p.m. Compare, e.g., Female lawyer, son ambushed in Mandaue (Cebu Daily News, Sept. 1, 2022) (8:50 p.m.) (“Female lawyer, son ambushed”),
https://cebudailynews.inquirer.net/461897/female-lawyer-son-ambushed-in-mandaue; What we know so far: The ambush of Cebu Port Authority lawyer Karen Quiñanola-Gonzales (Rappler, Sept. 6, 2022) (9:00 p.m.; stating that “[a] concerned citizen reported the incident at 9:20 pm to the Mandaue City Police”) (“What we know so far”), https://www.rappler.com/nation/visayas/what-we-know-so-far-ambush-cebu-port-authority-lawyer-karen-quinanola-gonzales/; Cebu lawyer, son hurt in ambush (Philippine Star, Sept. 3, 2022) (9:00 p.m.) (“Cebu lawyer, son hurt”), https://www.philstar.com/nation/2022/09/03/2206977/cebu-lawyer-son-hurt-ambush; Attack on Cebu lawyer, son among priority NBI cases (Advocates, Sept. 6, 2022) (9:00 p.m.) (“Priority NBI cases”),
https://www.advocatesomi.com/2022/attack-on-cebu-lawyer-son-among-priority-nbi-cases; and Lawyer, son ambushed in Mandaue City (Philippine Daily Inquirer, Sept. 2, 2022) (10:00 p.m.) (“Lawyer, son ambushed”), https://newsinfo.inquirer.net/1657192/lawyer-son-ambushed-in-mandaue-city; CHR sends team to probe attack vs lawyer in Mandaue City (Global Daily Mirror, Sept. 6, 2022) (10:00 p.m.) (“CHR sends team”), https://globaldailymirror.com/Main/full_article/chr-sends-team-to-probe-attack-vs-lawyer-in-mandaue-city25216; Lawyer, son ambushed in Mandaue (ABS-CBN News, Sept. 2, 2022) (“past 10 p.m.”) (“Lawyer, son ambushed in Mandaue”),
https://news.abs-cbn.com/news/09/02/22/lawyer-son-ambushed-in-mandaue. (All cites last accessed on Sept. 21, 2022).
[3] What we know so far, supra n.2; Lawyer, son wounded in gun attack in Mandaue City; IBP offers P50,000 reward for shooters (Manila Bulletin, Sept. 2, 2022) (“Lawyer, son wounded”), https://mb.com.ph/2022/09/02/lawyer-son-wounded-in-gun-attack-in-mandaue-city-ibp-offers-p50000-reward-offered-for-shooters/; NBI probing botched attack against lady lawyer, son in Mandaue City (Abogado, Sept. 6, 2022) (“NBI probing attack”), https://abogado.com.ph/nbi-probing-botched-attack-against-lady-lawyer-son-in-mandaue-city/; Cebu Port Authority lawyer ambushed in Mandaue City (Rappler, Sept. 2, 2022) (“CPA lawyer ambushed”), https://www.rappler.com/nation/visayas/cebu-port-authority-lawyer-ambushed-mandaue-city-september-2022/.
[4] CPA lawyer ambushed, supra n.3; What we know so far, supra n.2; Lawyer, son wounded, supra n.3; NBI probing attack, supra n.3.
[5] Police probe angles in shooting of lawyer, son in Cebu (ABS-CBN News, Sept. 4, 2022) (“Police probe angles”), http://news.abs-cbn.com/news/09/04/22/police-probe-angles-in-shooting-of-lawyer-son-in-cebu; Cebu Port Authority lawyer, son ambushed in Mandaue (CNN, Sept. 2, 2022) (“CPA lawyer, son ambushed”),
http://www.cnnphilippines.com/news/2022/9/2/Cebu-Port-Authority-lawyer-ambush-Mandaue.html; Priority NBI cases, supra n.2; Lawyer, son ambushed, supra n.2.
In addition to her work for the Port Authority, Quiñanola-Gonzales also maintains a private law practice. Police probe angles, supra n.5.
[6] CPA lawyer ambushed, supra n.3; CPA lawyer, son ambushed, supra n.5.
[7] IBP-Cebu City dangles P50,000 reward for information on suspects in ambush of lawyer in Mandaue City (Cebu Daily News, Sept. 2, 2022), https://cebudailynews.inquirer.net/461913/ibp-cebu-city-dangles-p50000-reward-for-information-on-suspects-in-ambush-of-lawyer-in-mandaue-city; Rama denounces ambush of lawyer and son in Mandaue City (Cebu Daily News, Sept. 2, 2022) (“Rama denounces ambush”), https://cebudailynews.inquirer.net/462035/rama-denounces-ambush-of-lawyer-and-son-in-mandaue-city.
[8] NBI probing attack, supra n.3; CPA lawyer, son ambushed, supra n.5; CPA lawyer, son shot (Yahoo News, Sept. 2, 2022) (“CPA lawyer, son shot”), https://ph.news.yahoo.com/cpa-lawyer-son-shot-125400254.html.
[9] CPA lawyer, son shot, supra n.8; What we know so far, supra n.2; NBI to probe ambush of Cebu port lawyer (SunStar, Sept. 6, 2022) (“NBI to probe ambush”), https://www.sunstar.com.ph/article/1939992/manila/local-news/nbi-to-probe-ambush-of-cebu-port-lawyer.
[10] CPA lawyer, son shot, supra n.8; NBI to probe ambush, supra n.9; Police probe angles, supra n.5; Rama denounces ambush, supra n.7; Mandaue police has POI in lawyer’s ambush (Cebu Daily News, Sept. 5, 2022) (“Mandaue police has POI”), https://cebudailynews.inquirer.net/462485/mandaue-police-has-poi-in-lawyers-ambush; CPA lawyer, son ambushed, supra n.5.
[11] Lawyer, son ambushed in Mandaue, supra n.2; Cebu lawyer, son hurt, supra n.2.
[12] CPA lawyer, son shot, supra n.8; Mandaue police has POI, supra n.10; CPA lawyer ambushed, supra n.3.
[13] What we know so far, supra n.2; Police probe angles, supra n.5.
[14] NBI probing attack, supra n.3; Priority NBI cases, supra n.2; Attack on Cebu lawyer, son among priority NBI cases (Philippine News Agency, Sept. 6, 2022) (“Attack among priority NBI cases”), https://www.pna.gov.ph/articles/1183008.
[15] Statement of CHR Executive Director, Atty. Jacqueline Ann de Guia, condemning the shooting of Cebu lawyer and son (Commission on Human Rights, Sept. 5, 2022) (“CHR Statement”), https://chr.gov.ph/statement-of-chr-executive-director-atty-jacqueline-ann-de-guia-condemning-the-shooting-of-cebu-lawyer-and-son/; CHR sends team, supra n.2; Attack among priority NBI cases, supra n.14; Priority NBI cases, supra n.2.
[16] Cops file complaint against suspected gunman in Cebu lawyer’s ambush (Rappler, Sept. 20, 2022), https://www.rappler.com/nation/visayas/cops-file-complaint-suspected-gunman-cebu-lawyer-ambush/.
[17] CPA lawyer, son shot, supra n.8; What we know so far, supra n.2; Police probe angles, supra n.5.
[18] FLAG condemns slay try on Cebu-based lawyer, son (Philippine Daily Inquirer, Sept. 3, 2022), https://newsinfo.inquirer.net/1657930/flag-condemns-slay-try-on-cebu-based-lawyer-son; CPA lawyer, son shot, supra n.8; CPA lawyer, son ambushed, supra n.5; What we know so far, supra n.2.
On June 30, 2022, Ferdinand (“Bongbong”) Marcos, Jr. succeeded Rodrigo Duterte as President of the Philippines. See Ferdinand Marcos Jr sworn in as Philippines president, replacing Duterte (BBC News, June 30, 2022).
[19] The IBP further urged authorities to consider providing protection for Quiñanola-Gonzales and her son until the assailants are in custody. See generally CPA lawyer ambushed (including a copy of the IBP Statement), supra n.3; IBP to gov’t: Intensify effort to protect lawyers (Politiko News, Sept. 8, 2022), https://politics.com.ph/2022/09/08/ibp-to-govt-intensify-effort-to-protect-lawyers/; IBP calls for nationwide effort to protect lawyers, judges (Malaya Business Insight, Sept. 8, 2022) (reporting that, in 2021, “the [Supreme Court] acknowledged the concerns raised by the IBP and other groups on violence targeting members of the legal profession and directed all lower courts to help law enforcement agencies in investigating them”), https://malaya.com.ph/news_news/ibp-calls-for-nationwide-effort-to-protect-lawyers-judges/; CPA lawyer, son ambushed, supra n.5; Police probe angles, supra n.5; Cebu lawyer, son hurt, supra n.2; CPA lawyer, son shot, supra n.8; Female lawyer, son ambushed, supra n.2.
[20] NUPL urges swift probe on lawyer’s ambush in Cebu (ABS-CBN News, Sept. 3, 2022) (“NUPL urges swift probe”), https://news.abs-cbn.com/news/09/03/22/nupl-urges-swift-probe-on-lawyers-ambush-in-cebu.
[21] CHR Statement, supra n.15; CHR sends team, supra n.2.
[22] See, e.g., Letter to President Duterte re: Continuing Attacks on Judges, Prosecutors, Lawyers, and Other Legal Professionals (New York City Bar, Aug. 28, 2019), https://www.nycbar.org/reports/letter-to-president-duterte-concerning-attacks-on-legal-professionals/; Submission to the Office of the U.N. High Commissioner for Human Rights Concerning Continuing Attacks Targeting Judges, Prosecutors, Lawyers, and Other Legal Professionals in the Philippines (New York City Bar, Jan. 31, 2020), https://www.nycbar.org/reports/submission-to-u-n-commissioner-for-human-rights-attacks-on-legal-professionals-in-the-philippines/.
[23] The referenced analysis documents that, between July 1, 2016 and June 30, 2022, there were at least 110 violent attacks on Filipino lawyers and paralegals – 90 attacks on judges, prosecutors, and lawyers, and 20 attacks on paralegals. As a result, 69 lawyers (including judges, prosecutors, and lawyers) were killed, and 21 survived. Of the 20 attacks on paralegals, 17 victims were killed, and three survived. See Lawyers and Human Rights Paralegals Attacked with Murderous Intent Under the Duterte Regime (June 30, 2022) (compiled by Gill H. Boehringer) (link available at The Philippines: Cebu Port Authority lawyer, son ambushed in Mandaue (International Association of People’s Lawyers, Sept. 2, 2022),
Due to minor differences in terminology and methodology, sources’ figures on attacks on legal professionals vary slightly. For example, according to the Integrated Bar of the Philippines, 63 lawyers were killed between 2016 and 2022, i.e., during the Duterte years. See IBP: Nationwide effort needed to deter attacks against lawyers (Global Daily Mirror, Sept. 7, 2022), https://globaldailymirror.com/Main/full_article/ibp-nationwide-effort-needed-to-deter-attacks-against-lawyers25266; see also, e.g., CPA lawyer ambushed (including link to Rappler List: Judges, prosecutors, lawyers killed under Duterte gov’t), supra n.3.
By any measure, the human toll is stunning.
[24] See generally United Nations Basic Principles on the Role of Lawyers (Sept. 7, 1990), https://www.ohchr.org/en/instruments-mechanisms/instruments/basic-principles-role-lawyers; CHR Statement (citing U.N. Basic Principles on the Role of Lawyers), supra n.15; cf. United Nations Basic Principles on the Independence of the Judiciary (Sept. 6, 1985), Principles 2, 4, & 11,
https://www.ohchr.org/en/instruments-mechanisms/instruments/basic-principles-independence-judiciary.
[25] See U.N. Basic Principles on the Role of Lawyers, Principle 18, supra n.24.
[26] See U.N. Basic Principles on the Role of Lawyers, Principle 16, supra n.24; see also NUPL urges swift probe (reporting that the NUPL Statement quoted Principle 16), supra n.20; cf. United Nations Basic Principles on the Independence of the Judiciary, Principles 2, 4, supra n.24.
[27] See U.N. Basic Principles on the Role of Lawyers, Principle 17, supra n.24; see also NUPL urges swift probe (reporting that the NUPL Statement quoted Principle 17), supra n.20; cf. United Nations Basic Principles on the Independence of the Judiciary, Principle 11, supra n.24.
[28] The international community’s profound dissatisfaction with the Philippine government’s response to the country’s continuing human rights crisis is in evidence at both the United Nations and the International Criminal Court. For example, with the U.N. Human Rights Council now in session in Geneva, the international community is urging the Council to adopt a strong new resolution on the Philippines, renewing calls for intensified U.N. scrutiny. And, in June, the International Criminal Court prosecutor submitted a request that the Court resume its investigation into the “drug war” killings in the Philippines, which the Court paused last November at the government’s request. The prosecutor’s request to reopen the investigation came after he concluded that the government has failed to take the necessary actions to ensure accountability at the domestic level. See, e.g., UN still needs to scrutinize the Philippines (Philippine Daily Inquirer, Sept. 12, 2022), https://opinion.inquirer.net/156881/un-still-needs-to-scrutinize-the-philippines; Human Rights Watch Briefing Paper Addressed to Member-states of the UN Human Rights Council Ahead of the Council’s 51st Session (Human Rights Watch, Sept. 8, 2022), https://www.hrw.org/news/2022/09/12/human-rights-watch-briefing-paper-addressed-member-states-un-human-rights-council; Philippines: Strong UN Human Rights Council Action Needed (Human Rights Watch, Sept. 12, 2022), https://www.hrw.org/news/2022/09/12/philippines-strong-un-human-rights-council-action-needed.
