Facts:

The case involves Rebecca B. Arnobit as the complainant and Atty. Ponciano P. Arnobit as the respondent. The events leading to the complaint began with their marriage on August 20, 1942, which produced twelve children. Rebecca supported Ponciano throughout his education in law school and his subsequent admission to the Philippine bar. However, in 1968, Ponciano left their home and began cohabiting with Benita Buenafe Navarro, with whom he fathered four additional children. This infidelity prompted Rebecca to file for legal separation and support, as well as a criminal case for adultery against both Ponciano and Benita. In his answer to the complaint, Ponciano acknowledged Rebecca as his wife and the mother of their children but denied cohabiting with Benita. He claimed that Rebecca's frequent travels for business were the cause of their separation, alleging neglect of her family duties. The case was brought before the Office of the Solicitor General and later the Integrat...

Facts:

Marriage and Family Background

• Rebecca B. Arnobit and Atty. Ponciano P. Arnobit were married on August 20, 1942.
• They had 12 children together.
• Rebecca supported Ponciano through law school until he passed the bar and became a lawyer.

Allegations of Abandonment and Immorality

• In 1968, Ponciano left the conjugal home and began cohabiting with Benita Buenafe Navarro, who bore him four children.
• Rebecca filed a complaint for legal separation and support, followed by a criminal case for adultery against Ponciano and Benita.

Respondent’s Defense

• Ponciano admitted Rebecca was his wife and the mother of their 12 children but denied cohabiting with Benita.
• He blamed Rebecca for their separation, claiming she neglected her family by traveling extensively for business without his consent.

Evidence Presented

• Rebecca presented:
  • Testimony from her sister, Venancia M. Barrientos, who identified a letter from Ponciano asking for forgiveness for causing unhappiness to his family.
  • Testimony from Melecio Navarro, Benita’s husband, who confirmed Ponciano’s illicit relationship with Benita.
  • Affidavits from NBI agents and documents (birth and baptismal certificates) proving Ponciano fathered four children with Benita.

Respondent’s Failure to Participate

• Ponciano repeatedly failed to appear at hearings, often citing illness, and did not submit affidavits or evidence to refute the allegations.

Issue:

1. Whether Atty. Ponciano P. Arnobit is guilty of abandonment of his family.
2. Whether Atty. Ponciano P. Arnobit is guilty of gross immorality for cohabiting with another woman and fathering illegitimate children.
3. Whether the acts of abandonment and immorality warrant disciplinary action, including disbarment.

Ruling:

• The Integrated Bar of the Philippines (IBP) found Ponciano liable for abandonment and recommended a three-month suspension.
• The Supreme Court disagreed with the IBP’s recommendation, finding that Ponciano’s actions constituted gross immorality, warranting disbarment.
• The Court ruled that Ponciano’s conduct violated the Code of Professional Responsibility, specifically Rule 1.01 (prohibiting immoral conduct) and Canon 7 (requiring lawyers to uphold the integrity of the legal profession).
• The Court emphasized that good moral character is a continuing requirement for lawyers and that Ponciano’s actions demonstrated a lack of such character.

Ratio:

1. Gross Immorality as Ground for Disbarment:

   • Immoral conduct, especially when gross and scandalous, is a valid ground for disbarment. Ponciano’s abandonment of his lawful wife and cohabitation with another woman, resulting in illegitimate children, constitutes gross immorality.
   • The Court cited jurisprudence stating that a lawyer’s misconduct, even if unrelated to professional duties, can justify disbarment if it shows unfitness for the legal profession.

2. Good Moral Character as a Continuing Requirement:

   • Lawyers must maintain good moral character not only at the time of admission to the bar but throughout their legal career. Ponciano’s actions failed to meet this standard.

3. Failure to Rebut Allegations:

   • Ponciano’s repeated failure to appear at hearings or present evidence to refute the allegations against him suggested an admission of guilt. His denial alone was insufficient to counter the clear and convincing evidence presented by Rebecca.

4. Disbarment as Appropriate Penalty:

   • The Court ruled that disbarment was the appropriate penalty, as Ponciano’s actions were a blatant violation of the moral and ethical standards required of lawyers. His conduct brought disrepute to the legal profession.

Conclusion:

• Atty. Ponciano P. Arnobit was disbarred, and his name was stricken from the Roll of Attorneys. The decision took effect immediately, and copies were circulated to relevant legal bodies.