The Supreme Court of the Philippines disbarred Atty. Amador B. Peleo III for gross unlawful, dishonest, and deceitful conduct, violating the Code of Professional Responsibility. This decision underscores that attorneys must uphold the highest standards of morality and honesty, both in their professional and private lives, and that a pattern of misconduct can lead to disbarment to protect the integrity of the legal profession.

When Professional Lines Blur: Faithlessness, Falsification, and a Lawyer’s Disregard

This case arose from a complaint filed by Marife A. Venzon against Atty. Amador B. Peleo III, alleging violations of the Code of Professional Responsibility and the Anti-Violence Against Women and Their Children Act. Venzon claimed that Peleo failed to provide child support for their son and engaged in various acts of dishonesty and immorality. The Integrated Bar of the Philippines (IBP) investigated the allegations and recommended Peleo’s disbarment, a decision ultimately upheld by the Supreme Court.

The Supreme Court’s decision rested on several key findings of misconduct. First, the Court found that Peleo maintained sexual relations with Venzon and other women while still married to his lawful spouse. The Court emphasized that while it generally does not interfere with a lawyer’s personal choices, Peleo’s pattern of faithlessness, particularly with a vulnerable client, posed a significant threat to the legal profession’s integrity. Citing precedent, the Court highlighted that engaging in illicit relations while married constitutes gross immorality, warranting disbarment. As seen in Guevarra v. Eala, 555 Phil. 713 (2007), the Court has consistently held lawyers accountable for conduct that violates Canon 1, Rule 1.01 and Canon 7, Rule 7.03 of the Code of Professional Responsibility.

CANON 1 – A LAWYER SHALL UPHOLD THE CONSTITUTION, OBEY THE LAWS OF THE LAND AND PROMOTE RESPECT FOR LAW OF AND LEGAL PROCESSES.

Rule 1.01 – A lawyer shall not engage in unlawful, dishonest, immoral or deceitful conduct.

Building on this principle, the Court addressed Peleo’s misuse of the legal process. Peleo had filed a petition for the declaration of nullity of his marriage but failed to prosecute it, using it merely to deceive Venzon into believing he would end his marriage. The Court condemned this as a violation of Canon 10, Rule 10.03 of the Code of Professional Responsibility, which prohibits lawyers from misusing rules of procedure to defeat the ends of justice. Lawyers, as officers of the court, have a duty to foster respect for court processes and ensure they are used for legitimate grievances, not personal whims.

CANON 10 – A LAWYER OWES CANDOR, FAIRNESS AND GOOD FAITH TO THE COURT

Rule 10.03 – A lawyer shall observe the rules of procedure and shall not misuse them to defeat the ends of justice.

Furthermore, the Court found Peleo guilty of falsifying entries in his son’s birth certificate, specifically the place and date of marriage. Falsification of a public document is a crime, and Peleo’s attempt to give the impression that his son was legitimate constituted fraud. The Court emphasized that lawyers must uphold truthfulness and honesty, as stated in Apolinar-Petilo v. Atty. Maramot, A.C. No. 9067, January 31, 2018: “The respondent cannot be relieved by his justifications and submissions. As a lawyer, he should not invoke good faith and good intentions as sufficient to excuse him from discharging his obligation to be truthful and honest in his professional actions.” This act alone seriously undermined his fitness to practice law.

The Court also noted Peleo’s repeated failure to provide child support, a legal obligation under the Family Code. As a parent, Peleo was duty-bound to provide for his son’s sustenance, education, and well-being. His failure to do so, coupled with his abusive behavior towards Venzon, demonstrated conduct unbecoming a member of the legal profession. In addition, Peleo showed serious disrespect for the IBP’s authority by disregarding an agreement brokered between him and Venzon. Canon 7 of the CPR mandates that lawyers uphold the integrity and dignity of the legal profession and support the activities of the integrated bar, which Peleo violated.

Canon 7. A lawyer shall at all times uphold the integrity and dignity of the legal profession and support the activities of the integrated bar.

Finally, the Court addressed Peleo’s fraudulent use of a Senior Citizen’s card, misrepresenting himself as being of age to avail of discounts. This dishonesty and fraud, a transgression of his lawyer’s oath, further demonstrated his lack of respect for the law. The Court stated, “His temerity in claiming he did it ‘for discount purposes only‘ shows an unscrupulous disregard and disrespect of the law which as a lawyer he ought to have been the first to uphold.”

Considering these multiple instances of unlawful, immoral, dishonest, and deceitful conduct, the Supreme Court concluded that Peleo had lost his fitness to continue as a member of the Bar. The Court emphasized that public confidence in the legal profession is eroded by the irresponsible conduct of its members, and Peleo’s actions directly undermined that confidence. By ordering his disbarment, the Court reaffirmed the high standards of ethical conduct expected of lawyers.

FAQs

What was the key issue in this case?	The key issue was whether Atty. Amador B. Peleo III’s conduct, including maintaining extramarital affairs, falsifying documents, and failing to provide child support, constituted gross misconduct warranting disciplinary action. The Supreme Court ultimately found his actions violated the Code of Professional Responsibility.
What is the Code of Professional Responsibility?	The Code of Professional Responsibility is a set of ethical rules that govern the conduct of lawyers in the Philippines. It aims to ensure that lawyers act with integrity, competence, and diligence, and uphold the dignity of the legal profession.
What does it mean to be disbarred?	Disbarment is the most severe form of disciplinary action against a lawyer. It means that the lawyer is permanently removed from the Roll of Attorneys and is no longer allowed to practice law.
Why was Atty. Peleo disbarred?	Atty. Peleo was disbarred for engaging in a pattern of misconduct, including maintaining extramarital affairs while married, falsifying entries in his son’s birth certificate, failing to provide child support, and misusing a Senior Citizen’s card. These actions violated the Code of Professional Responsibility.
What is considered as Gross Immorality for Lawyers?	For lawyers, gross immorality typically involves conduct that is so corrupt or unprincipled that it shocks the moral sense of the community. It often involves sexual misconduct, abuse of authority, or acts of dishonesty that demonstrate a lack of integrity.
What Canon of the CPR did Atty. Peleo violate?	Atty. Peleo was primarily found guilty of violating Rule 1.01, Canon 1 of the Code of Professional Responsibility, which states that a lawyer shall not engage in unlawful, dishonest, immoral, or deceitful conduct. He also violated Canon 7 and Canon 10.
How does this case affect other lawyers in the Philippines?	This case serves as a reminder to all lawyers in the Philippines that they must adhere to the highest ethical standards, both in their professional and private lives. Failure to do so can result in severe disciplinary actions, including disbarment.
Can a disbarred lawyer be reinstated?	Yes, a disbarred lawyer can apply for reinstatement to the Bar, but the process is rigorous. The lawyer must demonstrate that they have rehabilitated themselves and are now of good moral character. The Supreme Court ultimately decides whether to grant reinstatement.

This case underscores the importance of ethical conduct for lawyers and the serious consequences of failing to meet those standards. It serves as a stark reminder that lawyers must uphold the integrity of the legal profession and maintain public confidence through their actions.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: MARIFE A. VENZON VS. ATTY. AMADOR B. PELEO III, A.C. No. 9354, August 20, 2019