FACTS:
Complainant Patricia Figueroa filed a petition in 1971 to deny respondent Simeon Barranco, Jr. admission to the legal profession. Complainant alleged that she and respondent were sweethearts, had a child out of wedlock, and that respondent did not fulfill his promise to marry her. The facts were established through hearings in 1971. Complainant also failed to comment on a motion to take testimonies by deposition, leading to respondent's motion to dismiss, which was denied by the court. Respondent made several motions to dismiss the case, citing his election as a member of the Sangguniang Bayan and the length of time the case has been pending. The court resolved to dismiss the complaint in 1988 for failure of complainant to prosecute the case for an unreasonable period of time but later canceled respondent's scheduled oath-taking. The case was referred to the Integrated Bar of the Philippines (IBP) for investigation.
ISSUES:
- Whether the respondent's past actions, specifically having an illegitimate child with the complainant and not fulfilling a promise to marry, constitute gross immorality warranting permanent exclusion from the legal profession.
RULING:
- The Court ruled that the respondent's actions do not constitute gross immorality. While engaging in premarital sexual relations and making unfulfilled promises suggests doubtful moral character, these actions do not amount to grossly immoral conduct justifying suspension or disbarment. The Court observed that grossly immoral acts are those that are so corrupt or disgraceful as to be reprehensible to a high degree.
PRINCIPLES:
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Gross Immorality An act must be more than immoral; it must be so corrupt and disgraceful as to constitute a criminal act or be reprehensible to a high degree to justify suspension or disbarment from the legal profession.
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Moral Character for Legal Profession Even if an individual has engaged in behaviors that suggest doubtful moral character, these must meet a high threshold of immorality—beyond mere indiscretion—to justify preventing their entry into the profession.
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Consensual Sexual Relationships Mere consensual sexual relations between adults, devoid of deceit, even if resulting in an illegitimate child, do not necessarily warrant disciplinary action or exclusion from the legal profession.
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Revenge and Complaint Complaints motivated by revenge or bitterness may lack the substance required to impose severe professional sanctions, particularly when considerable time has elapsed without further indiscretion.
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Passage of Time Long periods without further immoral actions may mitigate past behaviors in considering admission to the legal profession.