JOCELYN DE LEON v. ATTY. TYRONE PEDRENA

FACTS:

The case revolves around a complaint filed by Jocelyn de Leon against Atty. Tyrone Pedreña for sexually harassing her. De Leon claimed that during a lunch meeting, Atty. Pedreña asked personal questions instead of discussing her case. After lunch, Atty. Pedreña offered her a ride which she initially refused, but he convinced her to get in the car. During the ride, he made unwanted advances such as holding her hand, attempting to insert his finger into her closed hand, and rubbing her leg. De Leon resisted but Atty. Pedreña persisted. She managed to unlock the car's door and disembarked at a particular location. On another office visit, De Leon did not see Atty. Pedreña. The IBP Investigating Commissioner recommended disbarment for Atty. Pedreña, finding that he violated the Code of Professional Responsibility by making sexual advances towards De Leon. The IBP Board of Governors adopted the recommendation but increased the suspension period from three to six months. Atty. Pedreña's motion for reconsideration was subsequently denied, and the case was forwarded to the Court for final approval.

ISSUES:

  1. Whether or not the lawyer is guilty of sexual harassment.

  2. Whether or not the lawyer should be disbarred or suspended from the practice of law.

RULING:

  1. The Integrated Bar of the Philippines (IBP) recommended the suspension of the lawyer from the practice of law for a period of six months. The IBP Board of Governors adopted and approved this recommendation. The Supreme Court noted the resolution of the IBP Board of Governors and affirmed the suspension.

PRINCIPLES:

  • A lawyer who commits overt acts of sexual harassment against a client may be suspended from the practice of law.

  • Disbarment cases can proceed independently of criminal cases based on the same facts.