Title
Supreme Court
De Ere vs. Rubi
Case
A.C. No. 5176
Decision Date
Dec 14, 1999
Atty. Rubi faced IBP disciplinary proceedings for gross immorality and misconduct after a romantic relationship with a client. Despite the complainant's withdrawal, the Supreme Court remanded the case for further investigation, emphasizing due process and the sui generis nature of lawyer disciplinary cases.

Case Digest (A.C. No. 5176)
Expanded Legal Reasoning Model

Facts:

In July 1997, Rita de Ere filed a complaint before the Integrated Bar of the Philippines (IBP) charging Atty. Manolo Rubi with gross immorality and misconduct. The allegations included:
  • Rubi’s alleged improper assistance to de Ere during her legal troubles beginning in 1991, which later evolved into a romantic relationship even though Rubi was a family man.
  • Rubi’s alleged representations that he was separated from his wife and would annul his marriage, leading de Ere to live with him publicly as husband and wife.
  • The subsequent incident when Rubi’s wife unexpectedly confronted de Ere at Rubi’s restaurant-residence, resulting in physical altercation and exposing discrepancies in Rubi’s representations.
Despite these serious allegations, Rubi failed to file an answer to the IBP’s order issued on August 21, 1997, which directed him to respond within ten days. Soon after, the complainant attempted to withdraw her petition. However, the IBP, relying solely on the allegations and Rubi’s silence—which it interpreted as an implicit admission—recommended his indefinite suspension.

Issues:

  • Whether the withdrawal of the complaint by the complainant should automatically terminate disciplinary proceedings against a lawyer.
  • Whether the failure of the respondent to file an answer to the IBP’s order can be treated as an admission of the facts alleged in the complaint.
  • Whether the IBP’s reliance solely on uncorroborated allegations, in light of the respondent’s silence, was sufficient to warrant the harsh disciplinary measure of indefinite suspension.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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