Facts:

• The case involves a disbarment complaint filed by Maryanne Merriam B. Guevarra-Castil against Atty. Emely Reyes Trinidad.
• Maryanne accused Atty. Trinidad of engaging in an adulterous affair with her husband, Orlando L. Castil, Jr.
• Both Atty. Trinidad and Orlando were officers of the Philippine National Police (PNP).
• The complaint was filed on November 29, 2013, after Maryanne discovered the affair and found a birth certificate indicating that Atty. Trinidad and Orlando had a child together.
• Maryanne alleged that Atty. Trinidad flaunted the affair and insulted her when confronted.
• Atty. Trinidad denied knowing Maryanne and claimed the complaint was based on hearsay and illegally obtained evidence.
• The Integrated Bar of the Philippines (IBP) Commission on Bar Discipline found Atty. Trinidad guilty of gross immorality and misconduct, recommending disbarment.
• The IBP Board of Governors adopted this recommendation, which Atty. Trinidad contested but was denied.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled that Atty. Emely Reyes Trinidad should be disbarred for gross immorality and misconduct, in violation of Canon 1, Rule 1.01, and Ca...(Unlock)

Ratio:

• The Court first addressed its jurisdiction over the case, noting that while it generally defers disbarment complaints against government lawyers to the appropriate administrative body, it retains jurisdiction if the misconduct affects the lawyer's fitness to practice law.
• The Court determined that Atty. Trinidad's actions, which included maintaining an adulterous affair and having a child with a married man, were grossly immoral and adversely reflected on her fitness to practice law.
• The Court emphasized that disbarment proceedings are sui generis, focusing on whether the lawyer is...continue reading