Case Digest (A.C. No. 8335) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Amalia R. Ceniza v. Atty. Eliseo B. Ceniza, Jr. (A.C. No. 8335, April 10, 2019), the complainant, Amalia R. Ceniza, and the respondent, Atty. Eliseo B. Ceniza, Jr., were married on November 12, 1989, in Cebu City and had two children. On April 21, 2008, the respondent left their home under the guise of attending a seminar and failed to return, taking his car and belongings. The complainant later learned from the respondent’s staff that he was cohabiting with a married woman, Anna Fe Flores Binoya, in Lapu-Lapu City. Despite confronting the respondent and refusing his attempt to nullify the marriage on grounds of psychological incapacity, the illicit relationship continued. The complainant filed a criminal administrative complaint with the Office of the Ombudsman, which found the respondent guilty of disgraceful and immoral conduct and suspended him for six months. The Ombudsman’s decision was affirmed by the Court of Appeals. Meanwhile, the Integrated Bar of the Philippines (... Case Digest (A.C. No. 8335) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Marriage and Family Background
- Amalia R. Ceniza (complainant) and Atty. Eliseo B. Ceniza, Jr. (respondent) were married on November 12, 1989 in Cebu City and had two children, Marie Agnes and Christopher Chuck.
- Respondent was employed as a legal officer at the Mandaue City Hall.
- Discovery of Extramarital Cohabitation
- On April 21, 2008, respondent left home claiming attendance at a Manila seminar; by April 26, 2008, he had moved out with his car and belongings.
- Complainant learned from respondent’s staff that he was cohabiting with Anna Fe Flores Binoya in Aldea Subdivision, Lapu-Lapu City; upon confrontation, respondent denied any wrongdoing.
- Parallel Proceedings
- July 9, 2008 – Respondent filed a nullity of marriage suit against complainant, alleging her psychological incapacity.
- November 2008 – Complainant filed an immorality complaint with the Office of the Ombudsman; April 2009 – escalated complaint to the Office of the Bar Confidant (OBC).
- August 5, 2011 – Ombudsman found respondent guilty of disgraceful and immoral conduct; imposed six-month suspension without pay.
- Court of Appeals affirmed Ombudsman decision; Integrated Bar of the Philippines Commission on Bar Discipline (IBP-CBD) and Board of Governors initially dismissed administrative case against respondent but later, upon complainant’s motions and OBC recommendations, re-opened investigation leading to SC review.
Issues:
- Whether the respondent’s abandonment of his lawful family and cohabitation with another married woman constitute gross immorality warranting disciplinary action.
- What penalty should be imposed if gross immorality is established.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)