Sapalo v. Diaz
REITERATIONFacts
The Antecedents: Complainant Jovita Sapalo filed an administrative complaint against respondent Rayfrando Diaz, alleging that they had amorous relations while students, resulting in her pregnancy. Respondent allegedly promised to marry her, even filing for a marriage license, but later withdrew the application and refused to marry her. Complainant gave birth to a child, Ma. Teresa Sapalo Diaz, whom respondent acknowledged and consented to be named as the father. Complainant later discovered respondent was already married. Procedural History: The Supreme Court required respondent to file an answer, which he did. Respondent admitted the amorous relationship and pregnancy but claimed it was consensual and without misrepresentation. He stated he resigned from his job to end the relationship and that he withdrew the marriage application papers after deliberation, realizing the marriage would be unhappy. He also stated he married his childhood sweetheart on December 25, 1968, and had no further relations with the complainant after April 15, 1968. A Court of First Instance decision, based on a stipulation of facts, declared the child as respondent's acknowledged natural child and ordered support. The Petition: The complainant subsequently filed a motion to withdraw her complaint, stating that the circumstances were truthfully set forth in the stipulation of facts from the recognition and support case. She admitted that both parties were to blame and that it would be unfair to blame only the respondent. The Supreme Court then required the Provincial Fiscal of Negros Occidental to verify the authenticity and voluntariness of the withdrawal. The Assistant Provincial Fiscal submitted transcript of stenographic notes showing the complainant personally appeared and affirmed the truthfulness and voluntariness of her petition to withdraw, stating she was not threatened or forced.
Issue(s)
Whether the administrative complaint should be dismissed based on the complainant's verified motion to withdraw. Whether the complainant's withdrawal of her complaint was made voluntarily and with full knowledge of the facts.
Ruling
The Supreme Court dismissed the administrative complaint against respondent Rayfrando Diaz.
Ratio Decidendi
On Issue 1: The Supreme Court dismissed the administrative complaint against respondent Rayfrando Diaz. This dismissal was predicated on the complainant's verified motion to withdraw her complaint. The Court considered the respondent's answer and the complainant's motion to withdraw, which sought the dismissal of the case. The Court's resolution to dismiss was further supported by the subsequent verification process. On Issue 2: The Supreme Court found that the complainant's withdrawal of her complaint was made voluntarily and with full knowledge of the facts. This was established through the investigation conducted by the 1st Assistant Provincial Fiscal of Negros Occidental, who forwarded the transcript of stenographic notes to the Court. In these notes, the complainant personally appeared and testified to the authenticity and voluntariness of her withdrawal. She affirmed the truthfulness and correctness of the allegations in her petition to withdraw and expressly stated that she was neither threatened nor forced into signing it. This verification process ensured that the withdrawal was not coerced and was made with informed consent, satisfying the requirements for the dismissal of an administrative case on such grounds.
Main Doctrine
The Supreme Court dismissed the administrative complaint against the respondent lawyer after the complainant voluntarily withdrew her complaint. The Court found that the withdrawal was authentic and voluntary, as evidenced by the complainant's sworn statements and the investigation conducted by the Provincial Fiscal. This dismissal aligns with the principle that administrative cases can be terminated when the complainant, with full understanding, seeks to withdraw the charges, especially when the underlying facts were admitted in a separate civil case.