Title
Abaigar vs. Paz
Case
Adm. Case No. 997
Decision Date
Sep 10, 1979
A lawyer was accused of deceit and immoral conduct by a client alleging he misrepresented his marital status, leading to a relationship. The Court dismissed the disbarment case due to insufficient proof and the complainant’s voluntary actions.

Case Summary (Adm. Case No. 997)

Background of the Complaint

On April 27, 1971, Pilar Abaigar initiated a formal disbarment complaint against David D.C. Paz after claiming he had misled her regarding the legality of marrying him. The events stemmed from a divorce case initiated by Abaigar's husband in California, wherein she sought legal assistance and allegedly entered into a romantic relationship with Paz, who professed love and proposed marriage, despite being civilly married to another woman.

Respondent’s Answer and Denial of Claims

In his response dated June 10, 1971, Paz denied any illicit relationship with Abaigar, arguing that she initially sought assistance through Congressman Bagatsing and that his interactions with her pertained exclusively to legal matters. He contended that she had solicited his help on various legal issues and that any perceived romantic relationship was unfounded.

Investigation and Findings

In a resolution dated August 20, 1971, the Court referred the case to the Solicitor General for investigation. The Solicitor General's report, submitted on June 30, 1973, indicated the complaint involved potential deceit and gross immoral conduct as defined by Section 27 of Rule 138 of the Rules of Court.

Analysis of Deceit and Legal Implications

The analysis considered whether Paz deceived Abaigar into believing they could legally marry despite existing marriages. The report noted that both parties were aware of their respective marital statuses, and highlighted that it would be implausible for someone of Abaigar's intelligence and educational background to misinterpret the law regarding the indissolubility of marriage, as divorce is not recognized in the Philippines.

Complainant’s Credibility and Inconsistencies

Abaigar's credibility was undermined by a subsequent letter she sent to Chief Justice Querube C. Makalintal, which contradicted her initial allegations of an illicit relationship, suggesting instead that her interactions with Paz were above-board. This inconsistency raised doubts about her motivations and the veracity of her claims.

Burden of Proof and Judicial Precedents

The court emphasized that the burden of proof lies with the complainant in disbarment proceedings. It reiterated that charges against a lawyer must be substantiated by convincing evidence and highlighted judicial precedents stating that any disbarment must rest on clear and unimpeachable evidence due to the serious consequences involved.

Dismissal of the Complaint

After thorough co

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