Case Digest (A.C. No. 3319) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Leslie Ui v. Atty. Iris Bonifacio, decided on June 8, 2000 under the 1987 Philippine Constitution, complainant Leslie Ui alleged that respondent Atty. Iris Bonifacio conducted an immoral relationship with her husband, Carlos L. Ui, whom she married on January 24, 1971, at Our Lady of Lourdes Church, Quezon City. The marriage produced four children. In December 1987, Leslie discovered that Carlos was cohabiting with respondent in Ayala Alabang and that they had a daughter born in 1986. Despite respondent’s assurances in June 1988 that their liaison had ended, Leslie found in December 1988 that respondent and Carlos had a second child and continued living together. Failing to cease their intimacy upon Leslie’s repeated entreaties, Leslie filed an administrative disbarment complaint on August 11, 1989 before the IBP Commission on Bar Discipline, charging respondent with gross immorality. Respondent admitted the relationship but claimed she thought Carlos was single, married him Case Digest (A.C. No. 3319) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Marriage and Family
- On January 24, 1971, Leslie Ui married Carlos L. Ui at Our Lady of Lourdes Church, Quezon City; they had four children: Leilani, Lianni, Lindsay, and Carl Cavin Ui.
- In December 1987, Leslie discovered Carlos was in an illicit relationship with Atty. Iris Bonifacio, with whom he had a daughter in 1986 and allegedly lived together at No. 527 San Carlos Street, Ayala Alabang Village.
- Respondent’s Version of Events
- Iris Bonifacio, UP Law ’82, admitted to meeting Carlos in 1983; believed him single despite his estranged Chinese children; married him in Hawaii on October 22, 1985.
- Upon return, did not cohabit with Carlos; left for Honolulu in 1986, returned June 1988; upon confrontation by Leslie, claimed the relationship was over and cut ties in July 1988; returned March 1989 with two children.
- Administrative and Criminal Proceedings
- August 11, 1989: Leslie filed Adm. Case No. 3319 for disbarment alleging immorality; Iris answered, counterclaimed for moral damages, and attached a marriage certificate dated 1985.
- Leslie filed criminal complaint for concubinage (I.S. No. 89-5247); Provincial Fiscal of Rizal dismissed for lack of proof of cohabitation; DOJ dismissed appeal for insufficiency of evidence.
- Leslie moved to cite Iris in contempt for false allegations and altered marriage certificate; Iris opposed, claimed good faith reliance on copy provided by Carlos.
- IBP Commission on Bar Discipline held hearings; parties filed memoranda in February and March 1995; Commission found Iris a victim of deception, no gross immorality, but noted the altered certificate.
- December 13, 1997: IBP Board of Governors adopted the Commission’s Report and Recommendation, dismissing the gross immorality complaint and reprimanding Iris for the falsified marriage certificate.
Issues:
- Whether respondent Atty. Iris Bonifacio’s relationship with married Carlos Ui constitutes “grossly immoral conduct” warranting disbarment.
- Whether respondent’s attachment of a marriage certificate with an intercalated date to her Answer constitutes misconduct or contempt meriting disciplinary sanction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)