Ventura v. Atty.

Samson
Facts
 Maria Victoria B. Ventura, then 13 years old, filed a complaint for disbarment against
Atty. Danilo S. Samson for grossly immoral conduct.
 She alleged that Samson sexually abused her twice—in December 2001 at his
house and on March 19, 2002 at his poultry farm in Agusan del Sur.
 Samson, then 38 years old and married, admitted having sexual intercourse with
Ventura but claimed it was with mutual consent and that he gave her money. He
argued that this did not amount to immoral conduct.
 The Provincial Prosecutor dismissed the rape charge but found probable cause for
qualified seduction.
 Later, Ventura and her mother executed affidavits of desistance, but the IBP still
pursued the disbarment case.
 The IBP Commission on Bar Discipline recommended 1-year suspension. The IBP
Board of Governors increased it to 5 years suspension with a stern warning.
 Both complainant and respondent sought reconsideration: Ventura asked for
disbarment, while Samson asked for a reduction of penalty.
Issue
Whether Atty. Danilo S. Samson’s acts of engaging in sexual relations with a 13-year-old girl
under his care constitute grossly immoral conduct warranting disbarment.
Ruling
 Yes. The Supreme Court DISBARRED Atty. Samson.
 The Court held that his act of having sexual intercourse with a minor, who was
entrusted to his care, is grossly immoral, disgraceful, and reprehensible.
 His admission that he gave her money in exchange for sex revealed moral depravity
and showed disrespect for the sanctity of marriage and human dignity.
 The fact that Ventura executed an affidavit of desistance did not absolve him
because disbarment cases are sui generis—they are not dependent on the wishes
of the complainant but are pursued to protect the public and preserve the integrity of
the legal profession.
 His conduct violated Canon 1, Rule 1.01 (prohibition against unlawful, dishonest,
immoral, or deceitful conduct) and Canon 7, Rule 7.03 (prohibition against scandalous
conduct) of the Code of Professional Responsibility, as well as his lawyer’s oath.
 Thus, the Court ruled that disbarment is the proper penalty, as suspension would
not suffice given the gravity of his misconduct.

Guevarra v. Eala
Facts
 Complainant: Joselano Guevarra filed a complaint for disbarment against Atty. Jose
Emmanuel “Noli” Eala for grossly immoral conduct. Eala, a married man, had an
illicit relationship with Guevarra’s wife, Irene Moje (also married at the time).
 Evidence showed:
o A handwritten love letter from Eala to Irene on her wedding day to complainant.
o Testimony that Eala and Irene were often seen together in public and even lived
together.
o Irene later gave birth to a child, with Eala named as the father in the birth
certificate.
 Eala admitted to having a “special relationship” with Irene but argued it was “low
profile” and not scandalous.
 IBP Investigating Commissioner: Recommended disbarment.
 IBP Board of Governors: Reversed and dismissed the case for lack of merit.
 Case was elevated to the Supreme Court.
Issue
Whether Atty. Eala’s extra-marital affair constitutes grossly immoral conduct warranting
disbarment.
Ruling
 YES. Atty. Eala is DISBARRED.
 His admitted adulterous relationship with a married woman, which bore a child,
constitutes grossly immoral conduct.
 The Court emphasized that:
o It is immaterial whether the affair was “low profile” or “scandalous” – adultery
itself is immoral.
o Extra-marital affairs manifest disrespect for marriage as a sacred institution
under the Constitution and the Family Code.
o Disbarment proceedings are independent of civil and criminal cases (e.g.,
annulment or adultery case).
 His acts violated:
 o Lawyer’s Oath (to uphold the Constitution and obey the laws).
o Canon 1, Rule 1.01 – a lawyer shall not engage in unlawful, dishonest, immoral,
or deceitful conduct.
o Canon 7, Rule 7.03 – a lawyer shall not engage in scandalous conduct
discrediting the profession.
Doctrine
 Grossly immoral conduct includes extra-marital affairs, even if carried out discreetly,
because they undermine marriage and reflect on a lawyer’s unfitness to remain in the
profession.
 Disbarment cases are sui generis – pursued to protect the public and preserve the
integrity of the bar, not dependent on complainant’s other legal actions.
✅Ruling:
Atty. Jose Emmanuel “Noli” Eala is DISBARRED for grossly immoral conduct,
violation of his oath, and violation of Canons 1 & 7 of the Code of Professional
Responsibility.

Vidaylin Yamon-Leach v. Atty. Arturo B. Astorga A.C. No. 5279, September 24, 2019
Facts:
Complainant, Vidaylin Yamon-Leach, entrusted ₱1.8M+ to her distant relative and family
lawyer, Atty. Arturo B. Astorga, to purchase a beach-front property in Leyte. Astorga forged
documents, misrepresented dead people as sellers, and misappropriated the money for
himself. Despite repeated demands and his promises to return the funds, Astorga failed to do
so. He also ignored multiple Supreme Court orders to file a comment, even after fines and
extensions. Records showed he had prior administrative cases (Nuñez v. Astorga; Saladaga v.
Astorga) where he was penalized for deceit and dishonesty.
Issue :
Whether Atty. Astorga should be disbarred for deceit, dishonesty, gross misconduct, and
violation of his Lawyer’s Oath and the Code of Professional Responsibility.
Ruling
YES. Atty. Astorga is DISBARRED.
His acts of fraud, deceit, forgery, and misappropriation of client’s money show a total lack of
honesty and integrity, making him unfit to remain in the Bar. His willful disobedience of
multiple Supreme Court directives constituted gross misconduct under Canon 12 CPR.
He violated:
Lawyer’s Oath (to obey laws, do no falsehood).
Canon 1, Rule 1.01 CPR – no unlawful, dishonest, immoral, deceitful conduct.
Canon 12, Rules 12.03 & 12.04 CPR – duty to assist in speedy administration of justice.
Membership in the bar is a privilege, not a right. His repeated misconduct and prior penalties
warranted the ultimate sanction.
Doctrine
A lawyer may be disbarred for deceit, malpractice, gross misconduct, violation of the
Lawyer’s Oath, or willful disobedience of court orders (Sec. 27, Rule 138, Rules of Court).
Good moral character is a continuing requirement for membership in the bar. Failure to obey
Supreme Court directives alone can be ground for suspension or disbarment.
✅ Ruling:
Atty. Arturo B. Astorga is DISBARRED. His name is ordered stricken from the Roll of Attorneys.

Judge Drilon & Atty. Romero v. Atty. Maglalang A.C. No. 13318, August 15, 2023
Facts
 Judge Drilon and Clerk of Court Romero charged Atty. Ariel Maglalang for fabricating
a spurious court order declaring one Ruby Madrinian presumptively dead in a non-
existent case.
 The forged order bore Judge Drilon’s name and fake signature.
 Complainant Jodee Andren testified that she paid Atty. Maglalang large sums (₱30,000
down, then ₱70,000 and ₱50,000) for her supposed annulment and related documents.
 In November 2006, Maglalang gave her the forged order, which she later found out to
be fake when her marriage record remained unchanged at the NSO.
 A witness, Nenita Kho-Artizano, corroborated seeing Maglalang hand over the forged
order.
 The NBI also confirmed that Maglalang gave the forged order to Andren.
 Maglalang denied knowing Andren and the witnesses but provided no convincing
rebuttal.
 IBP-CBD: Found him guilty, recommended 1-year suspension.
 IBP-BOG: Modified penalty to disbarment for falsifying court documents.
Issue
Whether Atty. Maglalang should be disbarred for fabricating and using a fake court order.
Ruling
  YES. Atty. Maglalang is DISBARRED.
 His acts constituted gross dishonesty, deceit, and falsification, which violated:
o Canon II (Sections 1, 2, 5, 8) – honesty, propriety, respect for the courts,
prohibition against misleading.
o Canon III, Sec. 2 – fidelity to law and the legal profession.
 A lawyer found in possession and use of a forged document is presumed to be the
forger, absent credible explanation.
 His bare denials were weak compared to sworn statements, documentary evidence, and
NBI findings.
 Falsifying court orders is a serious offense under the CPRA, meriting disbarment, as
in similar cases (Reyes v. Rivera, Taday v. Apoya, Jr.).
Doctrine
 Lawyers who falsify court orders or decisions commit a serious offense that
warrants disbarment.
 Possession and use of a forged court document, without satisfactory explanation, raises
the presumption that the lawyer is its author.
✅Ruling:
Atty. Ariel D. Maglalang is DISBARRED. His name is ordered stricken off the Roll of
Attorneys.
Adrian M. Kelley v. Atty. Cipriano D. Robielos III A.C. No. 13707, September 5, 2023 Per
Curiam
Facts
 In February 2016, Atty. Robielos borrowed ₱240,000 from Kelley and issued a check as
payment.
 The check bounced due to insufficient funds.
 They entered into a Kasunduan ng Pag-aayos where Robielos promised to pay in
₱20,000 installments every 15 days, but he only paid ₱60,000, leaving ₱180,000
unpaid.
 Kelley sued him in small claims court, which ruled against Robielos. Despite a writ of
execution, he still refused to pay.
 Kelley then filed an administrative complaint with the IBP.
 The IBP recommended suspension, but because Robielos had previous suspensions
for similar acts, the case was elevated to the Supreme Court.
Issue
Whether Atty. Robielos should be held administratively liable for issuing a worthless check
and refusing to pay his just debt.
Ruling
 Yes. Atty. Robielos is liable.
 The Court ruled that issuing a worthless check and refusing to pay a valid debt
constitutes gross misconduct and a violation of the Code of Professional
Responsibility and Accountability (CPRA):
o Canon II – Lawyers must act with honesty and propriety.
o Canon III – Lawyers must respect legal processes.
 His defense that the check was issued to “return a favor” was baseless since he
admitted partial payment.
 His repeated failure to comply with IBP orders showed disrespect for legal
processes.
 Considering his prior suspensions for similar misconduct, the Court imposed the
ultimate penalty of disbarment.
Doctrine
 Issuing worthless checks and deliberate failure to pay just debts constitute
gross misconduct punishable by suspension or disbarment.
 Good moral character is a continuing requirement for lawyers; repeated violations show
unfitness to remain in the Bar.
Disposition
 Atty. Cipriano D. Robielos III is DISBARRED.
 His name is ordered stricken from the Roll of Attorneys.
 He is fined ₱35,000 for ignoring IBP directives.
 He is also directed to pay his debt to Kelley in accordance with the writ of execution.

Adrian M. Kelley v. Atty. Cipriano D. Robielos III A.C. No. 13707, September 5, 2023 Per
Curiam

Facts

 In February 2016, Atty. Robielos borrowed ₱240,000 from Kelley and issued a check as
payment.
  The check bounced due to insufficient funds.

 They entered into a Kasunduan ng Pag-aayos where Robielos promised to pay in

₱20,000 installments every 15 days, but he only paid ₱60,000, leaving ₱180,000
unpaid.

 Kelley sued him in small claims court, which ruled against Robielos. Despite a writ of
execution, he still refused to pay.

 Kelley then filed an administrative complaint with the IBP.

 The IBP recommended suspension, but because Robielos had previous suspensions
for similar acts, the case was elevated to the Supreme Court.

Issue

Whether Atty. Robielos should be held administratively liable for issuing a worthless check
and refusing to pay his just debt.

Ruling

 Yes. Atty. Robielos is liable.

 The Court ruled that issuing a worthless check and refusing to pay a valid debt
constitutes gross misconduct and a violation of the Code of Professional
Responsibility and Accountability (CPRA):

o Canon II – Lawyers must act with honesty and propriety.

o Canon III – Lawyers must respect legal processes.

 His defense that the check was issued to “return a favor” was baseless since he
admitted partial payment.

 His repeated failure to comply with IBP orders showed disrespect for legal
processes.

 Considering his prior suspensions for similar misconduct, the Court imposed the
ultimate penalty of disbarment.

Doctrine

 Issuing worthless checks and deliberate failure to pay just debts constitute
gross misconduct punishable by suspension or disbarment.

 Good moral character is a continuing requirement for lawyers; repeated violations show
unfitness to remain in the Bar.

Disposition

 Atty. Cipriano D. Robielos III is DISBARRED.

 His name is ordered stricken from the Roll of Attorneys.

 He is fined ₱35,000 for ignoring IBP directives.

 He is also directed to pay his debt to Kelley in accordance with the writ of execution.

Re: Disbarment of Atty. Lorenzo “Larry” Gadon A.C. No. 13521, June 27, 2023

Facts

 Atty. Lorenzo “Larry” Gadon went viral after a video spread online where he was seen
hurling profanities and making misogynistic remarks against journalist Raissa
Robles.

 This was not the first time he was involved in misconduct; he had multiple pending
administrative cases for improper, abusive, and offensive behavior.

 The Office of the Bar Confidant (OBC), through the IBP, investigated and found his
repeated actions to be unbecoming of a lawyer and destructive to the image of the
legal profession.
Issue

Whether Gadon should be disbarred for repeated acts of vulgar, offensive, and disrespectful
conduct in violation of the Code of Professional Responsibility and Accountability
(CPRA).

Ruling

 Yes. Gadon is guilty.

 The Court held that his repeated use of vulgar language, offensive behavior, and public
misogynistic remarks constituted gross misconduct and serious violations of the
CPRA:

o Canon II (Propriety) – requires lawyers to maintain honesty, dignity, courtesy,

and propriety at all times.

o Canon III (Fidelity) – requires respect for the law, legal processes, and the
integrity of the legal profession.

 His conduct was not an isolated incident but part of a pattern of abusive
behavior, showing his unfitness to remain in the Bar.

 The Court stressed that a lawyer must behave in a manner that upholds the dignity of
the profession, both in private and public life.

Doctrine

 A lawyer may be disbarred for habitual abusive, vulgar, and offensive

conduct, even outside the courtroom, because membership in the Bar
requires continuous demonstration of good moral character.

 Lawyers are expected to serve as models of propriety and must avoid acts that bring
the profession into disrepute.

Disposition

 Atty. Lorenzo “Larry” Gadon is DISBARRED.

 His name is stricken off the Roll of Attorneys effective immediately.

Maria Victoria G. Belo-Henares v. Atty. Roberto "Argee" C. Guevarra A.C. No. 11394,
September 29, 2020

Facts

 Complainant: Dra. Vicki Belo (Maria Victoria G. Belo-Henares), Medical Director of Belo
Medical Group, Inc. (BMGI).

 Respondent: Atty. Roberto “Argee” Guevarra, counsel of a disgruntled patient who

sued Belo for an alleged botched cosmetic procedure.

 Instead of limiting himself to legal remedies, Guevarra made Facebook posts calling
Belo names like “quack doctor,” “Reyna ng Kaplastikan,” “Reyna ng Payola”, and
encouraged the boycott of Belo’s clinics.

 He even alleged corruption, bribery, criminal negligence, and threatened that Belo
would face prosecution.

 Belo filed a disbarment complaint, arguing that the remarks were vulgar, sexist,
malicious, and intended to ruin her reputation and business.

Issue

Did Atty. Guevarra violate the Code of Professional Responsibility (CPR) through his
Facebook posts?

Ruling

 Yes.
  The Supreme Court ruled that Guevarra’s posts were malicious, insulting, and
unbecoming of a lawyer, violating:

o Rule 7.03 – prohibits scandalous conduct that discredits the legal profession.

o Rule 8.01 – prohibits abusive or offensive language.

o Rule 19.01 – prohibits threatening unfounded criminal charges to gain

advantage.

 His defense that the posts were “private” on Facebook was rejected since he had
thousands of “friends” who could access, share, and spread them.

 The Court also ruled that freedom of expression is not absolute—a lawyer must
still observe propriety and decency.

 Being a public figure (celebrity doctor) does not excuse abusive, malicious, and sexist
attacks.

Doctrine

 A lawyer may be disciplined for offensive, scandalous, or vulgar behavior

even outside court, including on social media.

 The right to free speech is limited by a lawyer’s duty to uphold the dignity of the
profession.

Disposition

 Atty. Roberto "Argee" C. Guevarra SUSPENDED from law practice for 1 year.

 Stern warning: repetition will merit a harsher penalty.

In Re: Cunanan March 18, 1954

Facts

 A group of law graduates (including Cunanan) petitioned the Supreme Court for
admission to the Bar without taking the bar examinations.

 They invoked Republic Act No. 972, which allowed graduates of certain law schools
who had completed a prescribed curriculum and had sufficient government service to
be admitted as lawyers without examination.

 The law was passed by Congress, effectively exempting a group of law graduates from
taking the bar.

 The petitioners claimed that since they met the law’s requirements, they should
automatically be admitted to practice law.

Issue

Can Congress, through a law (RA 972), allow admission to the Bar without requiring a bar
examination, despite the Supreme Court’s authority over admission to the practice of law?

Ruling

 No. Petition denied.

 The Supreme Court struck down RA 972 as unconstitutional because:

o Under the Constitution, the power to regulate admission to the practice of

law belongs exclusively to the Supreme Court.

o Congress may enact laws relating to legal education, but it cannot interfere
with or diminish the Court’s authority to determine who may practice
law.

 The Bar Examination is an essential test of competence, moral character, and fitness
to become a lawyer.
  To admit law graduates without bar exams would undermine the integrity of the
legal profession.

Doctrine

 The power to admit, suspend, or disbar lawyers is vested exclusively in the

Supreme Court.

 Congress cannot pass a law exempting individuals from taking the bar
examination—that would be an encroachment on judicial power.

Disposition

 Petitioners (Cunanan and others) were NOT admitted to the Bar.

 RA 972 declared unconstitutional insofar as it attempted to exempt law graduates

from bar examinations.

Divine Grace P. Cristobal v. Atty. Jonathan A. Cristobal A.C. No. (Disbarment),

Carandang, J.

Facts

 Divine Grace (wife) filed a disbarment complaint against her husband, Atty.
Jonathan Cristobal, citing physical, verbal, emotional, and psychological abuse.

 She detailed several incidents (2005–2009) where Atty. Cristobal allegedly choked,
punched, pushed, and threatened her, sometimes in front of their children and
relatives.

 She supported her complaint with police blotters, medical certificates, and photos of
her injuries.

 Atty. Cristobal denied the allegations, presenting his own versions of the events and
affidavits from relatives. He claimed Divine was disrespectful, violent, and prone to
jealousy.

 IBP findings:

o Investigating Commissioner: recommended dismissal (mere domestic

squabbles, not scandalous).

o IBP Board of Governors: reversed; recommended disbarment (violence is

immoral and scandalous).

Issue

Is a lawyer’s violent behavior toward his spouse a ground for disbarment or disciplinary
action?

Ruling

 Yes, but not disbarment in this case.

 The Supreme Court held that domestic violence by a lawyer is a proper subject of
disbarment proceedings because a lawyer must maintain good moral character both
in private and professional life.

 Rule 1.01 (unlawful, dishonest, immoral, or deceitful conduct) and Rule 7.03
(scandalous conduct, discredit to the profession) of the CPR were violated.

 Substantial evidence proved at least three incidents of physical violence (Jan. 30,
2005; May 15, 2009; Dec. 11, 2009).

 BUT mitigating circumstances (provocations by wife, his role as provider, custody of

children, reconciliatory attempts by wife) prevented disbarment.

Doctrine

 A lawyer’s duty to maintain good moral character extends to private life,

including marital relations.
  Domestic violence by a lawyer = grossly immoral conduct and may be a ground
for discipline, even if the related criminal case is dismissed or compromised.

 Penalty of disbarment must be reserved for the gravest cases; mitigating

factors may justify suspension instead.

Disposition

 Atty. Jonathan Cristobal: SUSPENDED for 3 months from the practice of law.

 Warning: repetition will merit a harsher penalty, possibly disbarment.

⚖️This case is significant because it’s the first time the SC explicitly ruled that domestic
squabbles (esp. violence) can be the subject of disbarment proceedings.

Republic of the Philippines, represented by Solicitor General Jose C. Calida v. Maria

Lourdes P. A. Sereno
G.R. No. 237428, July 17, 2018

Facts

 Maria Lourdes Sereno was appointed Chief Justice of the Supreme Court in 2012 by
then-President Aquino.

 In 2018, the Solicitor General (Calida) filed a petition for quo warranto, alleging
Sereno was not qualified for the position because she:

o Failed to file her SALNs (Statement of Assets, Liabilities, and Net Worth) for
several years when she was a UP Law professor.

o Lacked the constitutional requirement of “proven integrity.”

 Sereno argued that:

o She could only be removed by impeachment under the Constitution.

o The petition was time-barred and violated the principle of separation of powers.

Issue

Can the Chief Justice (a constitutional officer) be removed from office through a quo
warranto petition, or only by impeachment?

Ruling

 Yes, a quo warranto petition is valid.

 The Supreme Court (8–6 vote) held that:

o While impeachment is the method of removing a validly appointed official for

wrongful acts committed while in office, quo warranto may be used to challenge
the validity of the appointment itself.

o Since Sereno’s failure to file SALNs showed she lacked integrity, she was
ineligible from the very beginning (void appointment).

o Therefore, she was never a valid Chief Justice, and quo warranto was proper.

Doctrine

 Impeachment is not the exclusive means of removing a member of the

Supreme Court; a quo warranto petition may be filed if the officer’s appointment
was invalid from the start.

 “Proven integrity” is a constitutional requirement for members of the judiciary, and

failure to file SALNs undermines integrity.

Disposition

 The Supreme Court declared:

 o Maria Lourdes P. A. Sereno is disqualified and ousted from the Office of
Chief Justice.

o The decision was immediately executory.

⚖️ This case is historic because it’s the first time in Philippine history that a sitting Chief
Justice was removed through quo warranto, not impeachment.

Manuel L. Valin and Honorio L. Valin v. Atty. Rolando T. Ruiz (Administrative Case,
Gesmundo, J.)

Facts

 Pedro Valin (father of complainants) owned land in Cagayan (OCT No. P-3275).

 Pedro died in 1992 in Hawaii. Years later, complainants discovered the land was
transferred to Atty. Rolando Ruiz, Pedro’s godson, via a Deed of Sale dated July
15, 1996.

 That deed supposedly bore Pedro’s and his wife Cecilia’s signatures — but Pedro was
already dead in 1996, while Cecilia was abroad.

 Even Pedro’s CTC used in the deed was falsified (issued in 1996, years after his death).

 Respondent Ruiz claimed he bought the land from Rogelio (another son of Pedro) way
back in 1989 for ₱26,000, but without any SPA. He insisted Rogelio handled the transfer
in 1996.

 Evidence showed Ruiz:

o Benefited from the falsified deed (title placed in his name, mortgaged land to
PNB).

o Directed his house helper to collect the TCT from the Registry of Deeds in 1996.

 IBP-CBD & IBP Board: found him liable; recommended 2 years suspension.

Issue

Is Atty. Ruiz guilty of misconduct (forgery/falsification of deed of sale) in violation of the

Lawyer’s Oath and the Code of Professional Responsibility?

Ruling

 Yes.

 Ruiz violated Rule 1.01 (no unlawful, dishonest, immoral, or deceitful conduct) and
Rule 10.01 (no falsehood or misleading of courts) of the CPR, as well as his lawyer’s
oath.

 His claim of good faith is not credible:

o He knew the 1989 sale was void (no SPA).

o He was Pedro’s godson → could not have been unaware of Pedro’s death in 1992.

o He directly benefited from the falsified 1996 deed.

 Even if done in his “private capacity,” lawyers are accountable for acts that taint
the profession’s integrity.

Doctrine

 A lawyer may be disciplined even for acts committed in private life if such acts
involve dishonesty or immorality.

 Being the beneficiary of a falsified deed, a lawyer is presumed its author unless
convincingly proven otherwise.

 Good moral character is a continuing requirement for membership in the bar.

Disposition
  Atty. Rolando T. Ruiz – SUSPENDED from law practice for 2 years.

 Stern warning: repetition will merit a heavier penalty, possibly disbarment.

⚖️This case reinforces that lawyers cannot hide behind “private transactions” to excuse
dishonesty or fraudulent acts.

Teresita B. Enriquez v. Atty. Trina De Vera (Resolution, Leonen, J.)

Facts

 Teresita (businesswoman) and Atty. De Vera (subcontractor for cell sites) were business
acquaintances.

 April 2006 – Atty. De Vera borrowed ₱500,000 (with ₱20,000 monthly interest). To
secure payment, she issued post-dated checks.

 She also borrowed ₱100,000 from Teresita’s sister (with Teresita as guarantor) and
issued another check.

 Upon maturity, the checks bounced (first for insufficient funds, then for closed
account).

 Teresita demanded payment, but Atty. De Vera failed to settle. Criminal complaints for
B.P. 22 (Bouncing Checks Law) and Estafa were filed.

 De Vera argued that the checks were not for loans but were only “guaranty checks” and
not meant to be encashed.

Issue

Is Atty. De Vera administratively liable for issuing worthless checks, constituting serious
misconduct under the Lawyer’s Oath and CPR?

Ruling

 Yes.

 The SC ruled that:

o Issuing worthless checks, even as “guaranty,” still violates B.P. 22 and

constitutes serious misconduct.

o As a lawyer, De Vera is presumed to know the law.

o Her claim of “show checks” is contrary to human experience and unsupported

by evidence.

 Violations:

o Canon 1, Rule 1.01 – no unlawful, dishonest, immoral, or deceitful conduct.

o Canon 7, Rule 7.03 – no conduct that adversely reflects on fitness to practice

law or discredits the profession.

 Lawyers may be disciplined even for private acts if these reveal dishonesty and
unfitness to remain in the profession.

Doctrine

 Issuance of worthless checks (B.P. 22 violation) by a lawyer constitutes

serious misconduct, regardless of whether conviction in a criminal case exists.

 Guaranty checks are still covered by B.P. 22.

 A lawyer must uphold integrity both in private and professional life.

Disposition

⚖️Atty. Trina De Vera – SUSPENDED from practice of law for 1 year.

Tita Mangayan v. Atty. Cipriano G. Robielos III (Disbarment Case, Gaerlan, J.)

Facts

 1995 – Respondent borrowed ₱594,185.00 from complainant, issued 4 postdated

checks (all bounced).

 Also borrowed ₱441,000.00 from complainant’s cousin, Elizabeth Macapia, again issuing
2 postdated checks (also bounced).

 Complainant later had to pay Macapia as co-maker.

 2016 – After being at large for years and later arrested, respondent signed a
Compromise Agreement with complainant and issued 4 replacement checks
totaling ₱500,000.00.

 He repeatedly sought extensions, then stopped communicating. The replacement

checks also bounced.

 In total, 10 worthless checks were issued by respondent.

 Respondent excused himself by saying he was just an “accommodation party” for a

friend, but also inconsistently claimed willingness to pay.

 He also ignored IBP directives and failed to attend mandatory hearings.

Issue

Is respondent administratively liable for gross misconduct (non-payment of just debts,

issuance of worthless checks, and defiance of IBP/SC orders)?

Ruling

 YES.

 Lawyers may be sanctioned for failure to pay just debts and issuing worthless
checks, whether in a professional or private capacity.

 Excuse of being an “accommodation party” is untenable—under the law, an

accommodation party is still primarily liable.

 His decades-long refusal to pay, issuance of multiple bad checks, and non-
cooperation with IBP proceedings show dishonesty, lack of integrity, and disrespect
for legal processes.

Doctrine

 Deliberate failure to pay just debts and issuance of worthless checks

constitute gross misconduct.

 Good moral character is a continuing requirement for lawyers.

 Disobedience to IBP/SC orders violates Canon 11 (respect for courts and legal
processes) and merits separate sanction.

Penalty / Disposition

⚖️Atty. Cipriano G. Robielos III is:

 SUSPENDED from law practice for 5 years, and

 FINED ₱10,000 for disobeying IBP/SC orders.

 Robielos III – 5 yrs suspension + ₱10k fine for 10 bouncing checks, unpaid debts, and
defiance of IBP/SC orders.

Dahlia S. Gacias v. Atty. Alexander Bulauitan A.C. No. 7280, November 16, 2006, Garcia,
J.

Facts

 Atty. Bulauitan owned land in Tuguegarao.

  1996 – He entered into a contract with complainant Gacias to sell a 92-sqm portion at
₱3,500/sqm (₱322,000 total).

 Gacias paid ₱300,000 in installments (almost full payment).

 Instead of delivering the title, respondent mortgaged the entire property to China
Bank without informing complainant.

 Bank later foreclosed and consolidated ownership.

 Gacias demanded return of her ₱300,000; respondent promised to reimburse but

never paid.

 She filed a complaint before the IBP and also a criminal case for estafa.

 Respondent argued the deal was purely private, not related to his being a lawyer, and
that Gacias did not fully pay the purchase price.

Issue

Is Atty. Bulauitan administratively liable for gross misconduct and dishonesty even if the
transaction was private?

Ruling

 YES.

 Lawyers can be disciplined for acts in their private life if such acts reveal dishonesty
and lack of integrity.

 Respondent received almost the entire consideration but mortgaged the property,
betraying complainant’s trust.

 His unfulfilled promise to return ₱300,000 was only a ploy to evade liability.

 This behavior shows dishonesty, fraud, and lack of moral fitness to remain in the
Bar.

Doctrine

 A lawyer may be suspended or disbarred for any misconduct—professional or private

—that demonstrates dishonesty, moral corruption, or unfitness to practice law.

 Failure to comply with just obligations under a contract, especially involving deceit,
constitutes gross misconduct.

Penalty / Disposition

⚖️ Atty. Alexander Bulauitan – SUSPENDED for 1 year from practice of law.

Bulauitan – 1 yr suspension for selling land, taking ₱300k, then mortgaging it → dishonesty in
private deal = gross misconduct.

Adrian M. Kelley v. Atty. Cipriano D. Robielos III (Disbarment Case):

Facts

 In 2016, Atty. Robielos borrowed ₱240,000 from Adrian Kelley and issued a check as
payment.

 The check bounced due to insufficient funds.

 They later signed a Kasunduan ng Pag-aayos, where Atty. Robielos promised to pay
in installments. He only paid ₱60,000, leaving a balance of ₱180,000.

 Kelley filed a small claims case; the court ordered Robielos to pay, but he refused.

 Despite writs of execution, Robielos continued to evade payment.

 Kelley then filed this administrative case before the IBP.

 Robielos ignored IBP’s orders and failed to file answers or attend proceedings.
Issue

Whether Atty. Robielos should be held administratively liable for:

1. Issuing a worthless check and failing to pay just debts; and

2. Ignoring lawful orders of the IBP.

Ruling

 Yes. The Supreme Court ruled that:

o Issuing a bounced check and refusing to pay debts show dishonesty and
gross misconduct, violating Canon II (Propriety) and Canon III (Fidelity) of
the CPRA.

o His repeated offenses and prior suspensions proved recidivism and unfitness to
remain in the legal profession.

o His defiance of IBP orders showed lack of respect for legal processes.

Penalty

 DISBARRED (name struck off from the Roll of Attorneys).

 ₱35,000 fine for disobeying IBP orders.

 Ordered to pay his debt to Kelley and comply with the writ of execution.

Doctrine

 Issuing worthless checks and failing to pay just debts constitute gross
misconduct and may warrant disbarment.

 A lawyer’s good moral character is a continuing requirement for membership in

the Bar.

 Disobedience to IBP orders is disrespect of judicial processes and punishable.

William S. Uy vs. Atty. Elerizza A. Libiran Meteoro, A.C. No. 13368 [Formerly CBD
Case No. 13-3851], May 21, 2024]

Facts

 2012 – Atty. Elerizza Libiran-Meteoro obtained a personal loan of ₱245,000 from

Maliliw Lending Corp. (represented by William Uy).
 She issued three post-dated checks as payment, two of which (₱122,500 each)
bounced due to “DAIF” (insufficient funds) and “Account Closed.”
 Uy tried to collect, but respondent ignored him.
 She had a prior suspension (6 months in 2014, Barrientos case) also for issuing
worthless checks.
 Despite IBP notices, she failed to appear, file an answer, or update her address with the
IBP.

Issue

1. Is Atty. Libiran-Meteoro liable for gross misconduct for issuing worthless checks?
2. Is she also liable for failing to update her IBP records and ignoring notices?

Ruling

 YES.
o Issuing unfunded checks violates BP 22 and constitutes unlawful, dishonest,
and deceitful conduct under Canon II, Secs. 1–2 of the CPRA.
o Her recidivism (repeat offense despite prior suspension) aggravated her liability.
o Her refusal to pay, hiding, and evading notices showed a pattern of fraud and
disregard for the law.
 She is also liable for violating IBP rules for not updating her address, which delayed
proceedings.
Penalty

⚖️DISBARMENT – name stricken off the Roll of Attorneys.

⚖️₱35,000 fine – for failure to update IBP records.
(Note: Debt of ₱245,000 is a civil matter; must be recovered through proper action, not in this
case.)

Doctrine

 A lawyer who repeatedly issues worthless checks commits gross misconduct

showing unfitness to remain in the Bar.
 Prior administrative liability is an aggravating circumstance that may justify
disbarment.
 Lawyers must update their IBP records; failure to do so is itself an administrative
offense.

👉 Quick Recall One-liner:

Libiran-Meteoro – repeat offender, issued bouncing checks again → DISBARRED + ₱35k fine
for failure to update IBP records.

Martin v. Atty. Ala, A.C. No. 13435, Feb. 5, 2025 (Kho, Jr., J.):

Facts

 Complainant Denis Guy Martin, a French national, was the ex-husband of

respondent’s sister.

 Martin accused Atty. Leticia Ala of:

1. Urging police officers to shoot her nephew Jean Marc during a 2017
altercation.

2. Using abusive and offensive language in pleadings before the Bureau of

Immigration in a deportation case she herself filed against Martin.

3. Representing conflicting interests (claiming she used information from her prior
role as counsel in her sister’s company).

 Ala had a prior case (A.C. No. 10556) where she was admonished for offensive
language.

 IBP found her liable for abusive language and improper conduct but no conflict of
interest; recommended admonition.

Issues

1. Is respondent liable for unlawful conduct (ordering police to shoot her nephew)?

2. Is she liable for using intemperate/abusive language in pleadings?

3. Is she guilty of representing conflicting interests?

Ruling

 YES – On unlawful conduct. She repeatedly urged police to kill Jean Marc, showing
disrespect for law and human rights, violating Canon II, Sec. 2 and Canon III,
Sec. 2 (CPRA).

 YES – On abusive language. Her pleadings were full of insults, accusations, and
offensive words—violating Canon II, Secs. 4 & 13 (CPRA).

 NO – On conflict of interest. She filed the deportation case in her personal capacity,
not as counsel, and there was no proof she misused confidential information.

Penalty

 6 months suspension – for unlawful conduct (ordering nephew shot).

 1 year suspension – for abusive language in pleadings.

  Penalties to be served successively.

 Stern warning – repeat violations will merit harsher sanctions.

Rojas v. Quiambao, A.C. No. 13496, June 4, 2024

Facts

 Atty. Merriam Fe Rojas (complainant) and Atty. Lovejoy Quiambao (respondent) were
married in 2005, managed a joint law office.

 2016: House helper AAA (18) revealed that Quiambao sexually harassed her (groping,
porn, masturbation, indecent proposals).

 Rojas investigated → 13 more victims (some minors, employees, helpers, secretaries).

 Victim CCC alleged she was drugged with tequila and raped multiple times.

 Victim DDD (secretary) said Quiambao repeatedly showed her porn and his genitalia.

 RTC issued a Permanent Protection Order (PPO) directing him to undergo

counseling for sex offenders.

 Later revealed: Quiambao had affairs with several women (BBB, CCC, HHH), sired
2 children with HHH, and even married HHH bigamously while still married to
complainant.

 IBP-CBD found him guilty of grossly immoral conduct and recommended disbarment.

Issues

1. Is Atty. Quiambao guilty of grossly immoral conduct?

2. What penalty should be imposed?

Ruling

YES. Guilty of 4 counts of Grossly Immoral Conduct (CPRA, Canons II & III):

1. Extramarital affairs with multiple women while married → Disbarment.

2. Bigamous marriage with HHH + 2 illegitimate children + flaunting paramour →

Disbarment + ₱100,001 fine.

3. Sexual harassment of AAA (house helper) → 3 years suspension + ₱150,000

fine.

4. Sexual harassment of DDD (secretary) → 3 years suspension + ₱150,000 fine.

🔹 Since disbarment already applies under Count 1, suspensions can’t be enforced but are
recorded for purposes of possible clemency/reinstatement.

Total fines: ₱400,001.

Doctrine

 Good moral character is a continuing requirement for lawyers; violations

(adultery, bigamy, sexual harassment) amount to gross immorality.

 Sexual harassment of subordinates = grave ethical violation showing moral

unfitness to remain in the Bar.

 Disbarment + fines may be imposed even for multiple counts, with suspensions
recorded for future clemency considerations.

👉 Memory cue: Quiambao — extramarital affairs, bigamy, sexual harassment → DISBARRED

+ ₱400,001 fines.
Re: Illegal Campaign and Activities in IBP–Central Luzon, A.M. No. 23-04-05-SC
(Divina), July 30, 2024 (Gaerlan, J.):

Facts

 An anonymous letter (March 2023) accused Atty. Nilo Divina, Dean of UST Law, of
spending millions on prohibited campaign activities for IBP–Central Luzon Governor (as
stepping stone to IBP National President).

 Allegations:

1. Sponsored trips of IBP-Central Luzon officers to Balesin (2022) and Bali (2023).

2. Distributed cash and Sodexo gift checks (₱50,000 each).

3. Funded IBP-Tarlac’s office renovation (₱2M).

 Atty. Jocelyn Clemente affirmed her “My Story” article claiming she was offered
positions and gift checks if Divina became governor.

 Respondents (various IBP officers) admitted trips but said they were team-building /
Christmas parties, not electioneering.

 Divina admitted sponsorships but denied campaigning, stressing he had no intention

to run as IBP Governor due to his UST Dean and law firm duties.

Issues

1. Did Atty. Divina commit prohibited campaign activities under Sec. 14, IBP By-
Laws?

2. Is he administratively liable for misconduct under the CPRA?

Ruling

1. NO.

o No evidence that Divina announced candidacy or sought the IBP-Central Luzon

governorship.

o Activities happened months before the election; at that time, delegates

(voters) had not even been elected.

o Trips were explained as team-building / alumni gatherings, not campaign

sorties.

o Unlike the 1989 IBP Elections Case, there was no clear intent to influence
voters.

2. YES.

o Even if not electioneering, extravagant sponsorships (foreign and luxury trips,

cash donations, renovations) created an appearance of impropriety and
undermined IBP’s integrity.

o Violated Canon II, Secs. 1 & 2, CPRA: lawyers must uphold integrity, avoid
conduct that erodes public confidence.

o Such acts amounted to Simple Misconduct, though not directly tied to

electioneering.

Penalty

 Guilty of Simple Misconduct.

 Fine: ₱500,000.00.

 Stern warning: repetition of similar acts will be dealt with more severely.

Doctrine

 The IBP is a public institution; its officers perform public functions and must
preserve integrity and independence.
  Sponsorships and financial generosity, even absent actual candidacy, can constitute
misconduct if they give the impression of patronage or compromise impartiality.

 Lawyers must avoid even the appearance of impropriety in professional or

organizational dealings.

👉 Memory cue: Divina – sponsored Balesin, Bali, big donations → not electioneering, but
Simple Misconduct, fined ₱500k.