Case Digest (G.R. No. 206666)
Facts:
In 1971, Patricia Figueroa filed a petition before the Supreme Court seeking to deny admission to the bar to Simeon Barranco, Jr., who had just passed the 1970 Bar Examinations on his fourth attempt. Both townmates of Janiuay, Iloilo, they had been sweethearts since their teens in 1953. Their consensual intimacy began around 1960 and in December 1964 resulted in the birth of an illegitimate son, Rafael Barranco. According to Figueroa, Barranco repeatedly promised to marry her once he passed the bar but ultimately wed another woman in 1971. Proceedings included hearings by Investigator Victor F. Sevilla in June–July 1971, authorized depositions in 1972, and multiple motions by Barranco to dismiss the complaint for abandonment and unreasonable delay, which the Court denied in 1974, 1980, and 1982. After an initial 1988 resolution dismissing the petition due to inordinate delay was set aside on Figueroa’s opposition, the case was referred to the Integrated Bar of the PhilippinesCase Digest (G.R. No. 206666)
Facts:
- Personal and Relationship Background
- Patricia Figueroa (complainant) and Simeon Barranco, Jr. (respondent) were townmates in Janiuay, Iloilo, and had been sweethearts since their teens in 1953; respondent even served as her escort when she was fiesta queen.
- Their consensual relationship began in 1960 and resulted in the birth of an illegitimate son, Rafael Barranco, on December 11, 1964.
- Promises, Conduct, and Child Support
- After passing the 1970 bar examinations on his fourth attempt (following unsuccessful attempts in 1966, 1967, and 1968), respondent repeatedly promised—over twenty to thirty times—to marry complainant once he was qualified to practice law.
- Despite these promises, respondent provided only minimal financial support (₱10.00 on the child’s birthdays) and, in 1971, married another woman, prompting complainant to file a petition to deny his admission to the bar on grounds of gross immorality.
- Procedural History
- 1971: Petition filed; hearings conducted by Investigator Victor F. Sevilla in June and July.
- 1974–1982: Respondent filed multiple motions to dismiss for procedural and substantive grounds; Court consistently denied dismissal (February 18, 1974; June 18, 1974; September 17, 1979; October 2, 1980; September 15, 1982).
- 1988: Respondent moved to dismiss and to allow oath-taking based on community standing and delay; Court initially granted but then rescinded the allowance on November 17, 1988, following complainant’s opposition.
- 1993–1997: Case referred to the Integrated Bar of the Philippines (IBP) for investigation; IBP report (May 17, 1997) recommended dismissal of the complaint and permission for respondent to take his oath.
Issues:
- Whether respondent’s premarital sexual relationship, birth of a child out of wedlock, and repeated broken promises to marry constitute “gross immorality” sufficient to permanently bar him from admission to the legal profession.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)