Case Digest (A.C. No. 2474) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1982, Eduardo M. Cojuangco, Jr. engaged Atty. Leo J. Palma as personal counsel after Palma had been handling his legal matters at ACCRA Law Offices. Palma became close to Cojuangco’s family and tutored the complainant’s twenty-two-year-old daughter, Maria Luisa, gaining extraordinary trust. On June 22, 1982, without family knowledge, Palma secretly married Maria Luisa in Hong Kong, falsely representing himself as a bachelor and securing travel expenses from the complainant’s office. Cojuangco learned that Palma was still married to Elizabeth Hermosisima with three children and that, to facilitate the Hong Kong union, Palma misrepresented his civil status to foreign authorities. On August 24, 1982, Cojuangco filed a petition for nullity of marriage in the Court of First Instance, which initially declared the marriage void ab initio but was later set aside and remanded by this Court. Meanwhile, on November 8, 1982, Cojuangco lodged a disbarment complaint alleging deceit, malpra Case Digest (A.C. No. 2474) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Relationship and Engagement
- Complainant Eduardo M. Cojuangco, Jr., a client of Angara Concepcion Regala & Cruz Law Offices (ACCRA), hired respondent Leo J. Palma as his personal counsel in the 1970s.
- Respondent became close to the Cojuangco family: he traveled and dined with them abroad and tutored complainant’s 22-year-old daughter, Maria Luisa Cojuangco (Lisa).
- Secret Marriage and Misrepresentations
- On June 22, 1982, without the family’s knowledge, respondent married Lisa in Hong Kong, falsely representing himself as a bachelor to foreign authorities.
- He procured a round-trip ticket from complainant’s office under the pretext of official business and assured complainant afterward that “everything is legal.”
- Legal Actions and Disbarment Proceedings
- On August 24, 1982, complainant filed a petition for nullity of marriage; the CFI declared the marriage void ab initio on November 2, 1982.
- Complainant lodged a disbarment complaint on November 8, 1982, charging deceit, malpractice, gross misconduct, violation of oath, and grossly immoral conduct.
- Respondent’s motion to dismiss (February 8, 1983) was denied; the case was referred to the Office of the Solicitor General (March 2, 1983) and then to the IBP Commission on Bar Discipline.
- After protracted delays, on March 20, 2003 the IBP commissioner found respondent guilty and recommended a three-year suspension; the IBP Board reduced this to one year.
Issues:
- Whether respondent’s secret bigamous marriage and related misrepresentations constitute grossly immoral conduct and a violation of his oath as a lawyer.
- Whether respondent’s acts warrant the penalty of disbarment.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)