AC 8335; (April, 2019) (Digest)
G.R. No. A.C. No. 8335. April 10, 2019. AMALIA R. CENIZA, Complainant, vs. ATTY. ELISEO B. CENIZA, JR., Respondent.
FACTS
Complainant Amalia R. Ceniza, the lawful wife of respondent Atty. Eliseo B. Ceniza, Jr., alleged that the respondent abandoned her and their two children in April 2008 to cohabit with a married woman, Anna Fe Flores Binoya. Despite her pleas, the respondent continued the illicit relationship. The complainant verified the cohabitation by confronting the respondent at his new address with Anna. The respondent subsequently filed a petition to declare his marriage null based on the complainant’s psychological incapacity. The complainant filed administrative complaints for immorality with the Office of the Ombudsman and the Office of the Bar Confidant.
The Office of the Ombudsman found the respondent guilty of disgraceful and immoral conduct and suspended him for six months, a decision affirmed by the Court of Appeals. The Integrated Bar of the Philippines Commission on Bar Discipline (IBP-CBD), however, recommended dismissal of the disbarment complaint, merely suggesting a warning. The IBP Board of Governors adopted this recommendation but deleted the warning.
ISSUE
Whether or not the respondent’s act of abandoning his lawful family to cohabit with a married woman constitutes gross immorality warranting disbarment.
RULING
Yes. The Supreme Court reversed the IBP’s recommendation and disbarred the respondent. The legal logic is anchored on the principle that good moral character is a continuing requirement for the practice of law. Gross immorality, as defined by conduct so willful and corrupt as to shock the community’s sense of decency, justifies the severest disciplinary action. The Court found the respondent’s abandonment of his family and open cohabitation with another married woman to be precisely such grossly immoral conduct. His actions demonstrated a blatant disregard for the sanctity of marriage and the ethical standards demanded of lawyers under the Code of Professional Responsibility, specifically Rule 1.01 (prohibiting unlawful, dishonest, immoral, or deceitful conduct) and Rule 7.03 (upholding the integrity and dignity of the legal profession).
The Court emphasized that the respondent’s status as a lawyer and a public official imposed a higher standard of morality. His defense of a mere business partnership with Anna was belied by the factual findings of cohabitation from the Ombudsman and the Court of Appeals. By choosing to maintain an illicit relationship, the respondent exhibited moral indifference unfit for the legal profession. Consistent with jurisprudence, such gross immorality warrants disbarment to preserve public confidence in the integrity of the bar. The penalty of disbarment was thus imposed, and his name was ordered stricken from the Roll of Attorneys.