Title
Supreme Court
Ceniza vs. Ceniza, Jr.
Case
A.C. No. 8335
Decision Date
Apr 10, 2019
Atty. Ceniza disbarred for gross immorality after abandoning family, cohabiting with a married woman, violating ethical standards.

Case Summary (A.C. No. 8335)

Procedural History

  1. April 2008: Respondent allegedly abandons family to cohabit with Anna Fe Flores Binoya.
  2. November 18, 2008: Complainant files immorality complaint with the Office of the Ombudsman.
  3. April 2, 2009: Complainant writes to the President; letter referred to the Office of the Bar Confidant (OBC).
  4. October 7, 2010: IBP Commissioner Hababag recommends dismissal of administrative complaint with warning.
  5. February 13, 2013: IBP Board adopts recommendation, deletes warning, and closes case February 26, 2014.
  6. June 4, 2014: Complainant files motion for reconsideration; Supreme Court refers case back to OBC and IBP.
  7. March 1, 2017: IBP Board denies reconsideration.

Ombudsman and Court of Appeals Findings

– Office of the Ombudsman (August 5, 2011) finds respondent guilty of disgraceful and immoral conduct, suspends him six months without pay.
– Court of Appeals (May 12, 2015) upholds suspension, finding ample circumstantial evidence of illicit cohabitation (overnight stays, affidavits of daughter and neighbors, vehicles parked at mistress’s residence).

Issue

Whether respondent’s abandonment of his lawful family and cohabitation with a married woman constitutes gross immorality warranting disciplinary action up to disbarment under the 1987 Philippine Constitution and the Code of Professional Responsibility.

Supreme Court’s Analysis

– The Supreme Court has inherent power under the 1987 Constitution to regulate the legal profession and enforce high moral standards.
– Gross immorality requires willful, flagrant, or shameless conduct that shocks public conscience and undermines confidence in the judiciary.
– Respondent’s mere denials, unsupported by evidence, fail to overcome the complainant’s substantial circumstantial proof.
– Findings by the Ombudsman and CA—daughter’s and neighbors’ affidavits, photographs, and respondent’s overnight stays—establish abandonment of wife and children to live with a married woman.

Violations of Ethical Rules

– Rule 1.01(a), Code of Professional Responsibility: prohibits unlawful, dishonest, immoral, or deceitful conduct.
– Rule 7.03(a), Code of Professional Responsibility: prohibits scandalous behavior adversely reflecting on fitness to practice.

Precedent and Principle

– Prior disbarment cases (Narag, Dantes, Bustamante-Alejandro, Guevarra) confirm that a lawyer who abandons family to maintain an illicit relationship exhibits lack of moral character a

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