Title
Valdez vs. Dabon, Jr.
Case
A.C. No. 7353
Decision Date
Nov 16, 2015
Atty. Dabon disbarred for gross immorality due to adulterous relationship with Sonia Valdez; claims of assault and intimidation deemed unsubstantiated.

Case Digest (A.C. No. 7353)
Expanded Legal Reasoning Model

Facts:

  • Parties and Complaint
    • Complainant Nelson P. Valdez filed an administrative complaint for disbarment against Atty. Antolin Allyson M. Dabon, Jr., a Division Clerk of Court at the Court of Appeals, on the ground of grossly immoral and indecent conduct.
    • The complaint alleged that Atty. Dabon carried on a long-term adulterous relationship with Nelson’s wife, Sonia Romero Valdez, involving sexual assaults, threats and intimidation.
  • Allegations of Nelson P. Valdez
    • Nelson and Sonia married in January 1998; Sonia worked as a CA court stenographer until May 2006.
    • In affidavits dated September 13, 2006, Nelson and Sonia alleged an affair from November 2000 to March 2006, maintained by respondent’s use of sleep-inducing drugs, sexual assault, and ongoing threats of exposure.
    • Supporting affidavits from Atty. Barrozo, Atty. Ligot, Virginia D. Ramos and Marie Iris Minerva corroborated Sonia’s account of harassment and persistent pursuit by respondent.
  • Position of Atty. Dabon
    • Respondent categorically denied all allegations of sexual assault, threats and intimidation, characterizing them as fabrications motivated by malice.
    • He contended that any relationship with Sonia was consensual friendship, supported by affidavits from Mary Jane Tulalian and Imelda Adan, and argued that Nelson lacked personal knowledge of the alleged nonconsensual acts.
  • IBP Investigation and Recommendation
    • On August 15, 2007, the Supreme Court referred the case to the Integrated Bar of the Philippines (IBP) for investigation.
    • Investigating Commissioner Manuel T. Chan found the charge of gross immoral conduct sufficiently proven and recommended disbarment; the IBP Board of Governors adopted this recommendation on December 11, 2008 and denied reconsideration in December 2012.

Issues:

  • Whether the evidence establishes that Atty. Dabon committed nonconsensual sexual assault and maintained the affair by threats and intimidation.
  • Whether Atty. Dabon’s extramarital relationship, even if consensual, constitutes gross immoral conduct warranting disbarment.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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