Facts:

The case at hand involves Maryanne Merriam B. Guevarra-Castil (the complainant) and Atty. Emely Reyes Trinidad (the respondent). The complaint was filed on November 29, 2013, alleging that Atty. Trinidad was engaged in an extramarital affair with Maryanne's husband, Orlando L. Castil, Jr. Both Orlando and Atty. Trinidad were officers of the Philippine National Police (PNP) and became acquainted through their professional duties. Maryanne initially dismissed rumors about their relationship but confronted Orlando in January 2009, at which point he admitted to the affair. In a desperate attempt to salvage her marriage, Maryanne reached out to Atty. Trinidad, requesting that she cease her relationship with Orlando. Instead of showing remorse, Atty. Trinidad allegedly insulted Maryanne, boasting about her legal profession and position within the PNP, and belittling Maryanne's worth.

Maryanne's marriage deteriorated following this confrontation, and she later discove...

Facts:

Background of the Case

The case involves a complaint filed by Maryanne Merriam B. Guevarra-Castil (Maryanne) against Atty. Emely Reyes Trinidad (Atty. Trinidad) for maintaining an extramarital affair with Maryanne's husband, Orlando L. Castil, Jr. (Orlando). Both Atty. Trinidad and Orlando were officers of the Philippine National Police (PNP).

Maryanne's Allegations

Maryanne alleged that she began receiving reports of the affair several years prior but chose to ignore them. In January 2009, Orlando confirmed the affair. Maryanne confronted Atty. Trinidad, who allegedly insulted her and boasted about her legal knowledge and position in the PNP. Atty. Trinidad allegedly told Maryanne, "kayang-kaya ko maging business[person] tulad mo, pero ikaw hindi mo kaya maging abogado tulad ko!" and "kahit na ipatanggal mo ako sa trabaho ko, lawyer pa rin naman ako."

Discovery of the Child

Maryanne later discovered a birth certificate indicating that Atty. Trinidad and Orlando had a child together. The birth certificate included an "Affidavit of Acknowledgment/Admission of Paternity" executed by Orlando. Atty. Trinidad allegedly flaunted her relationship with Orlando and their child online.

Atty. Trinidad's Defense

Atty. Trinidad denied knowing Maryanne personally or being aware of her relationship with Orlando. She claimed the complaint was based on hearsay and illegally obtained evidence. However, she admitted to "committing some acts which are not to be proud of."

Findings of the Commission on Bar Discipline

The Commission found Atty. Trinidad guilty of gross immorality and misconduct, violating Canon 1, Rule 1.01, and Canon 7, Rule 7.03 of the Code of Professional Responsibility (CPR). The Commission recommended disbarment.

IBP Board of Governors' Resolution

The IBP Board adopted the Commission's findings and recommended disbarment. Atty. Trinidad's Motion for Reconsideration was denied.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction Over Government Lawyers: The Court clarified its jurisdiction over government lawyers, stating that it has authority to discipline lawyers for acts that affect their fitness to practice law, regardless of their government position. The Court abandoned previous rulings that deferred jurisdiction to the Ombudsman or other agencies when the misconduct involved official duties.

2. Gross Immorality: The Court held that Atty. Trinidad's actions—maintaining an extramarital affair and flaunting it publicly—constitute grossly immoral conduct. Such behavior adversely reflects on her fitness to practice law and violates the CPR.

3. Disbarment as Penalty: The Court emphasized that disbarment is appropriate for grossly immoral conduct, especially when it involves a breach of trust and moral standards expected of lawyers. Atty. Trinidad's actions, including her failure to show remorse or provide a credible defense, warranted the ultimate penalty of disbarment.

4. Continuing Fitness to Practice Law: The Court reiterated that the fitness to be a lawyer is a continuing requirement, measured against the standards of the Lawyer's Oath and the CPR. Atty. Trinidad's actions demonstrated a clear failure to meet these standards.

Conclusion:

The Supreme Court disbarred Atty. Emely Reyes Trinidad for gross immorality, striking her name from the Roll of Attorneys. The decision serves as a reminder of the high ethical standards expected of members of the legal profession.