Case Summary (G.R. No. 135042)
Allegations and Initiation of Disbarment Proceedings
In December 1987, Leslie Ui discovered Carlos Ui’s relationship with Atty. Bonifacio, resulting in a 1986 child and a second child in December 1988. Upon petitioner’s confrontations in mid-1988 and March 1989, Respondent persisted in the illicit relationship and obtained employment with Carlos Ui’s company. Petitioner filed an administrative complaint for gross immorality before the IBP Commission on Bar Discipline on August 11, 1989.
Respondent’s Answer and Counterclaims
Respondent maintained she believed Carlos Ui to be single when they met in 1983, married him in Hawaii (allegedly October 22, 1985), and did not cohabit in the Philippines. She asserted that upon learning of his first marriage in June 1988 she severed ties and returned to Honolulu until March 1989. By counterclaim, she sought ₱10 million in moral damages for malicious prosecution.
Dismissal of Criminal Complaint for Concubinage
Meanwhile, a criminal complaint for concubinage was filed against Respondent and Carlos Ui in Rizal (I.S. No. 89-5247) but dismissed for lack of proof of cohabitation. The Secretary of Justice upheld the dismissal on appeal.
Marriage Certificate Discrepancy and Contempt Motion
Petitioner moved to cite Respondent for contempt, alleging she knowingly filed an altered marriage certificate showing October 22, 1985 instead of the true 1987 date, in violation of RPC Arts. 183 and 184. Respondent claimed she relied in good faith on the copy provided by Carlos Ui.
IBP Commission on Bar Discipline Findings
The Commission found credible Respondent’s belief in Carlos Ui’s bachelor status, her departure upon learning the truth, and absence of cohabitation after March 1989. It concluded that Respondent was more victim than perpetrator and that no willful, flagrant or shameless conduct warranting disbarment had been shown.
IBP Board of Governors’ Resolution
On December 13, 1997, the IBP Board adopted the Commission’s recommendation: dismiss the complaint for lack of merit but reprimand Respondent for knowingly attaching a falsified marriage certificate, with warning against repetition.
Legal Standards on Good Moral Character and Disbarment
Under the 1987 Constitution and the Rules of Court, admission to and retention in the Bar require continuous good moral character. Disbarment may follow “grossly immoral conduct,” defined as willful, flagrant or shameless acts reflecting moral indifference to community norms.
Supreme Court’s Assessment of Respondent’s Conduct
The Court agreed that Respondent, believing in the validity of her
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Parties and Nature of the Case
- Complainant: Leslie Ui; Respondent: Atty. Iris Bonifacio.
- Administrative disbarment complaint (A.C. No. 3319) filed before the Commission on Bar Discipline of the Integrated Bar of the Philippines.
- Ground: gross immorality—alleged illicit relationship with a married man (Carlos L. Ui) resulting in two (2) children.
Background Facts
- January 24, 1971: Leslie Ui married Carlos L. Ui at Our Lady of Lourdes Church, Quezon City; four (4) children followed.
- December 1987: Complainant discovered husband’s affair with Atty. Iris Bonifacio; first child born in 1986.
- Respondent: UP College of Law graduate, admitted to the Philippine Bar in 1982.
- Carlos Ui admitted the relationship; respondent initially told complainant in June 1988 that the affair had ended.
Continuation of the Affair
- December 1988: Birth of a second child to respondent and Carlos Ui.
- March 1989: Complainant again pleaded with respondent to end the relationship; respondent refused.
- Complainant learned respondent was employed by Carlos Ui in his company.
Administrative Disbarment Proceedings
- August 11, 1989: Disbarment complaint docketed as Adm. Case No. 3319 before the IBP Commission on Bar Discipline.
- Allegation: respondent’s immoral conduct in carrying on an illicit relationship with a married man.
Respondent’s Answer and Counterclaim
- Met Carlos Ui in 1983, believed him a bachelor with estranged children in China.
- Claimed marriage in Hawaii on October 22, 1985; lived separately to allow his children to adjust.
- Alleged discovery of his true civil status in June 1988; broke off all ties and returned to Honolulu until March 1989.
- Denied cohabitation at Ayala Alabang; stated she lived in her mother’s house at No. 527 San Carlos Street.
- Counterclaimed for moral damages of ₱10,000,000.00 for malicious, groundless disbarment action.
Criminal Proceedings and Dismissals
- Complainant filed a concubinage charge (I.S. No. 89-5247) before the Provincial Fiscal of Rizal; dismissed for lack of