G.R. No. A.C. No. 11104, June 9, 2020
ROGELIO PASAMONTE, COMPLAINANT, VS. ATTY. LIBERATO TENEZA, RESPONDENT.

FACTS

Complainant Rogelio Pasamonte filed an administrative complaint for disbarment against Atty. Liberato Teneza. Pasamonte alleged that Atty. Teneza, who had been his lawyer in ejectment cases and was a family friend, planned and arranged Pasamonte’s marriage to Mary Grace dela Roca on June 9, 2006, despite knowing Pasamonte was already married. Atty. Teneza assured him the marriage would not be registered. Later, Atty. Teneza assisted Mary Grace in filing bigamy and violation of R.A. No. 9262 cases against Pasamonte. Pasamonte also discovered that Atty. Teneza himself had contracted a second marriage with Charina dela Roca on July 3, 1993, while his first marriage to Victoria Reyes (April 18, 1979) was still subsisting. Further, Atty. Teneza acted as a wedding sponsor in two marriages of Francisco dela Roca III in 2004 and 2007. Pasamonte accused Atty. Teneza of violating the lawyer-client relationship, engaging in a bigamous marriage, and meddling with civil registry processes.
In his defense, Atty. Teneza admitted being Pasamonte’s lawyer but denied violating the lawyer-client relationship, claiming the bigamy case was unrelated to the prior ejectment cases. He admitted to the two marriages but claimed good faith, alleging he had not heard from his first wife since 1983. He also admitted being a wedding sponsor but explained it was upon the brides’ request so he could testify if the marriages failed. The Integrated Bar of the Philippines Commission on Bar Discipline (IBP-CBD) found Atty. Teneza wanting in integrity and initially recommended a two-year suspension. The IBP Board of Governors increased the penalty to disbarment.

ISSUE

Should Atty. Teneza be disbarred from the practice of law due to his alleged immoral acts?

RULING

Yes, the Supreme Court affirmed the IBP Board of Governors’ recommendation and ordered Atty. Teneza’s disbarment.
The Court held that possession of good moral character is a continuing requirement for law practice, mandated by Canon 1, Rule 1.01 and Canon 7, Rule 7.03 of the Code of Professional Responsibility. Atty. Teneza committed grossly immoral conduct by contracting a second marriage while the first was subsisting. Marriage contracts are public documents enjoying a presumption of regularity, and Atty. Teneza’s own admission in a counter-affidavit proved the bigamous marriage. His claim of good faith was rejected; as a lawyer admitted in 1976, he cannot feign ignorance of the law requiring a judicial declaration of nullity before remarrying. This act alone renders him unfit for the bar.
Furthermore, his actions in arranging Pasamonte’s bigamous marriage and acting as a sponsor in marriages that appeared bigamous demonstrated a blatant disregard for the sanctity of marriage and the law. Such conduct adversely reflects on his fitness to practice law, constitutes malpractice, and violates his oath. The Court found the penalty of disbarment appropriate, citing precedents where lawyers were disbarred for bigamous marriages and grossly immoral conduct. His name was ordered stricken from the Roll of Attorneys.