Case Digest (G.R. No. 196102)
Facts:
In Re Charges of Lilian F. Villasanta for Immorality v. Hilarion M. Peralta, G.R. No. L-9513, April 30, 1957, Supreme Court En Banc, Paras, C.J., writing for the Court. The petition is an administrative proceeding seeking to disqualify the respondent from admission to the bar on grounds of immorality.The complainant was Lilian F. Villasanta; the respondent was Hilarion M. Peralta, a successful 1954 bar candidate. The Court considered the records of a related criminal prosecution (the same G.R. No. L-9513) that arose from Villasanta’s criminal complaint.
Chronologically, the respondent was married to Rizalina E. Valdez on April 16, 1939, in Rizal, Nueva Ecija. Before March 8, 1951, Peralta courted Villasanta and procured a blank marriage contract which he caused her to sign on March 8, 1951. About a week later the document was returned to Villasanta, bearing signatures of a Justice of the Peace, the Civil Registrar of San Manuel, Tarlac, and two witnesses. Thereafter the parties lived together as husband and wife. On July 7, 1951, they underwent a religious ceremony in Aparri; the parish priest did not require a marriage license because the civil marriage contract was presented.
Villasanta later discovered that Peralta’s earlier marriage to Valdez remained subsisting. She filed a criminal action for violation of Article 350 of the Revised Penal Code (bigamy) in the Court of First Instance of Cagayan. The respondent was convicted; the conviction was affirmed by the Court of Appeals; Peralta’s certiorari petition to this Court was dismissed for lack of merit. Separately, Villasanta filed the present administrative complaint in this Court charging immorality and seeking disqualification from admission to the bar.
The Supreme Court, on the basis of the criminal records and the complaint, found the respondent’s co...(Subscriber-Only)
Issues:
- Does the respondent’s conduct and his conviction for conduct proscribed by Article 350 of the Revised Penal Code establish moral turpitude sufficient to show lack of the good moral character required for admission to the bar?
- Should the respondent be disqualified from admission to the bar on th...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)