Barrientos v. Daarol
REITERATIONFacts
The Antecedents: In 1969, Transfiguracion Daarol, a married man and General Manager of ZANECO, befriended Victoria Barrientos, then a teenager. In June 1973, with her parents' consent, Daarol invited Barrientos to be an usherette at a Masonic convention. He courted her, representing himself as single and living alone. On July 7, 1973, Barrientos accepted his proposal of love after he promised to marry her in December. On August 20, 1973, after a party, Daarol took Barrientos to a secluded beach where, through reiterated promises of marriage and claims that 'December is very near,' he induced her to have sexual intercourse. This occurred multiple times thereafter, resulting in Barrientos' pregnancy. When informed, Daarol suggested abortion, which Barrientos refused. He then promised to marry her in Manila to avoid scandal. Procedural History: In October 1973, in Manila, Daarol finally confessed he was already married but claimed he had been estranged for 16 years and would seek an annulment. He provided minimal support but eventually deserted Barrientos and their child, Dureza, born in June 1974. Barrientos initially filed an administrative case with the National Electrification Administration (NEA), which was referred to the Zamboanga del Norte Electric Cooperative (ZANECO) and subsequently dismissed. The Petition: Barrientos filed a sworn complaint for disbarment with the Supreme Court on August 20, 1975, on the grounds of deceit and grossly immoral conduct. Respondent Daarol argued that the relationship was consensual, that the complainant's family knew of his prior marriage, and that as a Moslem convert, he was entitled to multiple wives, though he admitted he could not marry the complainant (a Christian) without committing bigamy.
Issue(s)
Whether respondent Transfiguracion Daarol is guilty of deceit in his relationship with the complainant, warranting disbarment. Whether respondent Transfiguracion Daarol is guilty of grossly immoral conduct in his relationship with the complainant, warranting disbarment.
Ruling
ACCORDINGLY, We find respondent Transfiguracion Daarol guilty of grossly immoral conduct unworthy of being a member of the Bar and is hereby ordered DISBARRED and his name stricken off from the Roll of Attorneys.
Ratio Decidendi
On the Issue of Deceit: The Court found that respondent used deceit to satisfy his sexual desires at the expense of a gullible 20-year-old student. The Court rejected respondent's claim that the complainant knew of his marriage, noting that he lived alone and never introduced his son to her family, which would be inconsistent with the behavior of a respectable family allowing their daughter to date a married man. Furthermore, the Court found respondent's moral sense 'seriously impaired' by his suggestion of abortion and his statement that he saw nothing wrong with the relationship despite being married. Regarding the 'Moslem convert' defense, the Court ruled it was a 'dubious claim' and legally irrelevant; even if he were a convert, he admitted he could not marry the complainant without committing bigamy, thus he knew a legal impediment existed. On the Issue of Immoral Conduct: Applying Pangan v. Ramos, the Court held that making love to another woman while a first marriage is valid and existing is contrary to honesty, justice, decency, and morality. Citing Piatt v. Abordo, the Court emphasized that good character is a continuing qualification, and respondent's acts of deceit, breach of promise, and desertion of his child demonstrated moral delinquency. Consequently, the Court determined that respondent exhibited a debased morality that rendered him unfit to remain an officer of the court.
Main Doctrine
The requirement of good moral character is a continuing qualification for the practice of law. When a lawyer's character is so deficient as to show that he is unsafe and unfit to be entrusted with the powers of an attorney, the Court retains the power to discipline or disbar him. Grossly immoral conduct is not limited to criminal acts but includes conduct that is willful, flagrant, or shameless, and which shows a moral indifference to the opinion of the good and respectable members of the community.