A.C. No. 10021-22 - AAA vs. Atty. Antonio N. de los Reyes

AAA was hired as a secretary by respondent Atty. Antonio De Los Reyes at the National Home Mortgage Finance Corporation (NHMFC).
Her rapid promotion to a plantilla position was facilitated by respondent Atty. De Los Reyes, establishing an early dependency and power imbalance.

Starting in the last quarter of 1997, respondent offered to use his NHMFC-issued service vehicle to bring AAA home, establishing a daily routine despite AAA’s residential status changing over time.
The relationship evolved from professional to personal wherein respondent became increasingly possessive, controlling telephone communications, and frequently summoning AAA to his office with personal stories and love notes.
His behavior vacillated between verbal abuse (cursing and shouting invectives) and overly solicitous behavior, contributing to an oppressive work environment.

AAA refused the respondent’s offer to drive her home, leading him to react angrily by shouting a profanity (“putangina mo”).
He blocked her path, grabbed her arm, and forcibly dragged her to the parking area where he pushed her into his service vehicle, driving off against her pleas.
During the incident, he slapped her twice before eventually abandoning her, an episode AAA reported to the police and informed her superior, Atty. Fermin Arzaga.

Despite her attempt to resign on December 22, 1998, AAA was persuaded to reconsider and was re-assigned, largely due to the manipulation by respondent who controlled her transfer and maintained her employment.
AAA, as the sole breadwinner supporting her family, felt compelled to continue her job, thereby enduring continuous sexual harassment and exploitation.
Over time, respondent intensified his abuse, isolating AAA from coworkers, and using his authority to force her into a position where she inevitably became his sexual slave, subjected to various forms of sexual misconduct ranging from abusive advances in his vehicle to coerced sexual intercourse in his office.

In subsequent years, including a notable period in 2003, respondent maintained close surveillance over AAA even during her official study leave; personally or through his driver he ensured her movements were controlled.
Instances included unwelcome public pursuit where he attempted to display their continued association, further escalating AAA’s humiliation and distress.
When AAA attempted to fend off respondent’s advances by flaunting a relationship with another man, respondent redirected his harassment towards AAA’s friend and colleague, forcing AAA to intervene.

AAA filed administrative complaints alleging sexual harassment and gross immoral conduct, presenting detailed accounts and corroborative witness testimonies from her colleagues.
Her allegations were supported by a Complaint-Affidavit filed on November 19, 2004, which described the sustained abuse and its impact on her mental and physical health, including diagnoses of Major Depressive Disorder and Post-Traumatic Stress Disorder.
Respondent Atty. De Los Reyes denied the allegations, claiming inconsistencies in her accounts, the absence of detailed particulars, and even invoked prescription of the alleged acts due to the lapse of time.

The Investigating Commissioner of the Integrated Bar of the Philippines (IBP) found respondent guilty of violating Rule 1.01 of the Code of Professional Responsibility, noting that AAA’s compliance with the sexual demands was driven by fear of reprisals.
Based on his findings, an initial recommendation of a one (1) year suspension was made.
The IBP Board of Governors, upon further review, adopted the Investigating Commissioner’s report with modifications and imposed an indefinite suspension on Atty. De Los Reyes.

During the June 30, 2006 hearing, the Transcript of Stenographic Notes (TSN) revealed AAA’s harrowing testimony, where she admitted to being forced into sexual intercourse repeatedly, describing the acts as rape performed under duress.
The TSN provided clear evidence that AAA’s consent was a product of coercion, given that her refusal threatened her continued employment, thereby confirming the abusive dynamics.

The Court referenced several cases (e.g., Ventura v. Samson, Tumbaga v. Teoxon, Zaguirre v. Castillo) to illustrate the spectrum of penalties imposed in instances of sexual misconduct and gross immorality.
Emphasis was placed on the necessity of maintaining high moral standards in the legal profession, with disciplinary actions serving as a deterrent against behavior that discredits the Bar and the justice system.

Whether respondent Atty. De Los Reyes committed acts amounting to sexual harassment and gross immoral conduct in violation of the Code of Professional Responsibility.
Whether the abuse of his position and authority to force AAA into non-consensual sexual relations, under the threat of job termination, amounts to misconduct that warrants disciplinary action.
Whether the evidence, including AAA’s detailed testimony and corroborative discrepancies in the respondent’s defenses, substantiates the imposition of disbarment as the appropriate sanction.