Case Digest (A.C. No. 13132)
Facts:
The case involves complainant Teodora Altobano-Ruiz and respondents Attys. Wilfredo A. Ruiz, Cherry Anne Dela Cruz, and Francisco S. Benedicto III. The complaint was filed before the Integrated Bar of the Philippines (IBP) - Commission on Bar Discipline (CBD) on January 31, 2023. Teodora accused the respondents of various violations of the Code of Professional Responsibility (CPR), including Canon 1, Canon 7, Canon 10, Canon 12, Canon 17, Canon 18, and Canon 19. The allegations stemmed from a series of synchronized acts of harassment against her, particularly by Atty. Ruiz, her estranged husband.
On June 4, 2008, Teodora filed a case against Atty. Ruiz for violating Republic Act No. 9262, known as the Anti-Violence Against Women and Their Children Act, and sought a Permanent Protection Order (PPO). The Regional Trial Court Branch 162 in Pasig City ruled in her favor on September 10, 2008, granting the PPO, which included provisions for support and protection from Atty. Rui...
Case Digest (A.C. No. 13132)
Facts:
- Complainant Teodora Altobano-Ruiz initiated a complaint before the Integrated Bar of the Philippines (IBP) - Commission on Bar Discipline (CBD) seeking the disbarment of three respondent lawyers:
- Atty. Wilfredo A. Ruiz
- Atty. Cherry Anne Dela Cruz
- Atty. Francisco S. Benedicto, III
- The complaint alleged violations of the Code of Professional Responsibility (CPR) including, but not limited to:
- Canon 1 (Rules 1.01 and 1.02) – engaging in unlawful, dishonest, immoral, or deceitful conduct
- Canon 7 (Rule 7.03) – conduct that adversely affects a lawyer’s fitness to practice
- Canon 10 (Rules 10.01 and 10.03) – duty of candor and avoidance of misleading the court
- Canon 12 (Rules 12.02 and 12.04) – prohibition against delaying cases or misusing court processes
- Canons 17, 18 (Rules 18.02 and 18.04), and 19 (Rule 19.01) – duties to the client and fair legal practice
Background of the Complaint
- Initiation of Legal Proceedings
- On June 4, 2008, the complainant sued her husband/respondent Atty. Ruiz under Republic Act 9262 (Anti-Violence Against Women and Their Children Act) and applied for a Permanent Protection Order (PPO).
- The Regional Trial Court Branch 162, Pasig City, ruled in her favor on September 10, 2008, granting a detailed PPO that included:
- Measures against harassment and further acts of violence
Chronology of Events and Actions
- The complainant presented extensive documentary evidence, including copies of the court’s PPO, the entry of judgment, the writ of execution, and the MAU with Radelia.
- The allegations against Atty. Ruiz included:
- Deliberate evasion of court orders via false addresses
- Entering into an illegal and immoral agreement (MAU) with Radelia which implicitly aimed at denying support to his minor child
- Consistent non-compliance with obligatory support orders, thus perpetuating economic, emotional, and psychological abuse.
Submission of Evidence and Alleged Misconduct
Issue:
- Whether his repeated failure to provide support to the complainant and their minor child, despite a final and executory court order, constituted a violation of CPR, particularly under Rules 1.01, 10.01, 10.03, and 12.04.
- Whether his act of deliberately providing false addresses and entering into an illicit memorandum (MAU) with his mistress to hide his assets and evade legal obligations amounts to economic abuse and a broader pattern of immoral and deceitful conduct.
Liability of Atty. Wilfredo A. Ruiz
- Whether the participation of these lawyers in related cases and their representation strategies can be construed as part of a conspiracy to commit synchronized acts of harassment against the complainant.
- Whether their actions rose to the level of administrative misconduct warranting disbarment or any sanction under the CPR.
Involvement of Atty. Cherry Anne Dela Cruz and Atty. Francisco S. Benedicto, III
- Whether the complainant established by substantial evidence the repeated and deliberate evasion of court orders by Atty. Ruiz.
- Whether the alleged misconduct of co-respondents was sufficiently proven to support administrative penalties.
Adequacy and Relevance of the Evidence
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)