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LESLIE UI v. ATTY. IRIS BONIFACIO

FACTS:

Complainant Leslie Ui, who was married to Carlos Ui, discovered in 1987 that her husband was having an illicit relationship with Atty. Iris Bonifacio, resulting in the birth of a child in 1986. Respondent admitted to having a child with Carlos Ui but claimed their relationship was over. However, complainant later learned that the relationship continued, and another child was born in December 1988. Complainant pleaded with respondent to end the relationship, but her pleas were in vain. In August 1989, complainant filed a complaint for disbarment against respondent before the Commission on Bar Discipline. Respondent, on the other hand, asserted that she married Carlos Ui abroad and only learned of his marriage to complainant in 1988. A criminal charge of Concubinage against respondent and Carlos Ui was dismissed due to lack of evidence.

In the complaint, Leslie Ui alleged that Atty. Iris Bonifacio conducted herself immorally and violated the Revised Penal Code. She claimed that she lived with Carlos Ui until he left in 1988 and that Atty. Bonifacio submitted an altered and intercalated marriage certificate to the Integrated Bar of the Philippines (IBP) to falsely state that she was married to Carlos Ui in 1985. However, the certificate of marriage revealed that their marriage took place in 1987. Leslie Ui argued that these actions showed moral perversity and lack of integrity, making Atty. Bonifacio unfit to be a member of the Philippine Bar. Atty. Bonifacio, on the other hand, maintained that she did not have the original copy of the marriage certificate and relied in good faith on the copy she possessed. She also claimed to be a victim in the situation, as she was unaware of Carlos Ui's existing marriage and ended the relationship upon discovering the truth.

ISSUES:

  1. Whether Atty. Iris L. Bonifacio conducted herself in an immoral manner, making her deserving of disbarment.

  2. Whether attaching a falsified Certificate of Marriage to her Answer constitutes an action meriting disciplinary action.

RULING:

The Supreme Court ruled as follows:

  1. The complaint for disbarment based on alleged immorality is dismissed. The Court found that her relationship with Carlos Ui, which she believed was a valid marriage, cannot be considered immoral given the lack of evidence to prove that she knew of his true civil status before getting involved with him.

  2. Atty. Iris L. Bonifacio is reprimanded for attaching to her Answer a photocopy of her Marriage Certificate with an altered date, accompanied with a stern warning that a more severe sanction will be imposed for any future similar offenses.

PRINCIPLES:

  1. Good Moral Character: A prerequisite for both admission to and maintenance in the legal profession. Continuous possession of good moral character is necessary for the enjoyment of the privilege of law practice.

  2. Grossly Immoral Conduct: Conduct that is willful, flagrant, or shameless, showing moral indifference to societal norms and respectable community opinion, and is sufficient to warrant disbarment.

  3. Burden of Proof in Disbarment: The burden of proving charges in disbarment proceedings rests on the complainant and must be established by clear, convincing, and satisfactory evidence.

  4. Professional Conduct of Lawyers: Lawyers must adhere to the highest standards of morality and professional ethics and any deviation, especially involving misleading the court or public, deserves sanction.