Case Digest (A.C. No. 10372)
Facts:
In A.C. No. 10372, Aurora R. Ladim, Angelito A. Ardiente and Danilo S. Dela Cruz vs. Atty. Perla D. Ramirez, the complainants—employees of Lirio Apartments Condominium in Makati City—filed in 2007 a complaint for disbarment against respondent Atty. Perla D. Ramirez arising from numerous incidents between 1990 and 2007. These episodes included unwarranted door knockings, impertinent personal questions, unauthorized entries into units under repair, use of offensive language against tenants and maintenance staff, accusations of prostitution, and refusal to pay condominium dues since 2004. The Integrated Bar of the Philippines (IBP) Commissioner, suspecting mental issues, recommended only a reprimand, which the IBP Board of Governors adopted. Viewing a mere reprimand insufficient, the Supreme Court, in a July 30, 2014 Resolution, suspended Atty. Ramirez for six months for violating Canon 7.03 of the 1987 Constitution-based Code of Professional Responsibility, warning that a repeat oCase Digest (A.C. No. 10372)
Facts:
- Parties and antecedents
- Complainants Aurora R. Ladim, Angelito A. Ardiente, and Danilo S. Dela Cruz are employees of Lirio Apartments Condominium in Makati City; respondent Atty. Perla D. Ramirez resides in the same condominium and is a long-time former State Prosecutor.
- In 2007, Ladim et al. filed a disbarment complaint against Atty. Ramirez for a series of unruly and offensive behaviors spanning 1990–2007.
- Summary of misconduct
- Repeated intrusions into condominium units (personal questions, knocking on doors, offensive language), unauthorized entries during repairs (lost keys), and refusal to pay association dues since 2004.
- Latest episodes involved shouting at maintenance staff and security guards, accusing residents of being prostitutes and of destroying property.
- Disciplinary history and post‐suspension events
- IBP Commissioner recommended a reprimand (possible mental issues); IBP Board adopted it.
- Supreme Court suspended Atty. Ramirez for six months (July 30, 2014) for violating Canon 7.03 of the Code of Professional Responsibility; warned that repetition would be dealt with more severely.
- From April 2016 to March 2018, respondent sought lifting of suspension without filing the required motion or sworn statement; she questioned OBC’s authority and refused to comply with directives.
- On March 15, 2017, during a follow-up at the Office of the Bar Confidant (OBC), Atty. Ramirez insulted Bar Confidant Atty. Cristina B. Layusa with expletives and derogatory remarks, witnessed by OBC staff and a security guard.
- An Incident Report (March 16, 2017) was submitted; despite two Supreme Court resolutions ordering her to comment, respondent did not reply.
- OBC’s July 16, 2019 Report and Recommendation advised denying lifting of suspension and disbarring Atty. Ramirez for gross misconduct.
Issues:
- Whether respondent Atty. Perla D. Ramirez should be disbarred from the practice of law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)