AM 674; (October, 1977) (Digest)
G.R. No. A.M. No. 674 October 2, 1977
Teresita Banzuela, complainant, vs. Atty. Jose C. Tabiliran, Jr., respondent.
FACTS
On June 4, 1965, Teresita Banzuela, an eighteen-year-old college student, filed a verified administrative complaint against Atty. Jose C. Tabiliran, Jr. The complaint alleged that the respondent lawyer, who was admitted to the bar in 1964, had promised to marry her. Relying on this promise, she surrendered her virtue and subsequently became pregnant. The respondent filed an answer to the complaint in 1965 pursuant to a resolution of the Court, but this document was inexplicably not attached to the case record.
ISSUE
The central issue is whether the respondent lawyer should be administratively disciplined based on the complainant’s allegations of a breached promise to marry, and whether subsequent events have rendered the complaint moot.
RULING
The Court dismissed the case. The legal logic proceeds from the nature of administrative proceedings for lawyers and the effect of supervening events. While a lawyer’s conduct in personal affairs may reflect on fitness for the profession, the primary purpose of disbarment or suspension is to protect the public and the integrity of the legal system, not to adjudicate private grievances or enforce purely personal contracts like promises of marriage. The complainant’s allegations, if proven, could potentially implicate moral character. However, the respondent, in a motion to dismiss dated September 9, 1977, presented a certified copy of a marriage certificate showing that he and the complainant were married on March 7, 1966, at the Saint Francis Xavier Church in Katipunan, Zamboanga del Norte. This fact of marriage constitutes a supervening event that fundamentally alters the context of the complaint. The alleged wrong—the failure to fulfill a promise to marry—has been cured by the subsequent solemnization of the marriage itself. The marital union effectively resolves the personal grievance at the heart of the administrative charge. Consequently, continuing the proceedings would serve no practical purpose for the protection of the public or the legal profession, as the core complaint has been rendered moot and academic by the parties’ own actions. The case was therefore ordered dropped and considered closed.