Title
Garrido vs. Garrido
Case
A.C. No. 6593
Decision Date
Feb 4, 2010
Lawyers Angel E. Garrido and Romana P. Valencia are disbarred for gross immorality after engaging in extramarital affairs and multiple marriages, violating the requirement of good moral character for membership in the legal profession.
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Case Digest (A.C. No. 6593)

Facts:

  • Maelotisea Sipin Garrido filed a disbarment complaint against Attorneys Angel E. Garrido and Romana P. Valencia.
  • Maelotisea married Atty. Angel Garrido on June 23, 1962, at San Marcelino Church, Ermita, Manila.
  • They had six children together.
  • In May 1991, Maelotisea discovered Atty. Angel Garrido had another family with Atty. Romana Valencia.
  • Atty. Angel Garrido married Atty. Romana Valencia in Hong Kong in 1978.
  • Atty. Angel Garrido left the conjugal home in June 1993 and did not provide financial support to his children.
  • Atty. Angel Garrido claimed his marriage to Maelotisea was void as he was already married to Constancia David when he married Maelotisea.
  • He also argued his marriages and children were before he became a lawyer.
  • Atty. Valencia denied being a mistress, asserting Maelotisea was not the legal wife of Atty. Angel Garrido.
  • The IBP Committee on Discipline recommended disbarment for Atty. Angel Garrido but dismissed the case against Atty. Valencia.
  • Atty. Angel Garrido sought relief from the Supreme Court, claiming he did not commit gross immorality and that the offenses had prescribed.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court disbarred Atty. Angel E. Garrido for gross immorality.
  2. The Supreme Court also disbarred Att...(Unlock)

Ratio:

  • The Supreme Court upheld the IBP Board of Governors' findings against Atty. Angel Garrido, noting his conduct was grossly immoral.
  • Good moral character is a continuing requirement for membership in the legal profession.
  • Atty. Angel Garrido's multiple marriages, extramarital affairs, and failure to provide financial support to his children demonstrated a pattern of grossly immoral...continue reading

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