ARCATOMY S. GUARIN, Complainant, v. ATTY. CHRISTINE A.C. LIMPIN, Respondent.

RESOLUTION

In 2004, Guarin was hired by Mr. Celso G. de los Angeles as Chief Operating Officer and thereafter as
President of OneCard Company, Inc., a member of the Legacy Group of Companies. He resigned from his
post and transferred to St. Lukes Medical Center as the Vice President for Finance.
In, 2008, Atty. Limpin, the Corporate Secretary of Legacy Card, Inc. (LCI), another corporation under the
Legacy Group, filed with the SEC a GIS for LCI for updating purposes. The GIS4identified Guarin as
Chairman of the Board of Directors (BOD) and President.
Mired with allegations of anomalous business transactions and practices, on December 18, 2008, LCI applied
for voluntary dissolution with the SEC.
On July 22, 2009, Guarin filed this complaint with the Integrated Bar of the Philippines Commission on Bar
Discipline (IBP CBD) claiming that Atty. Limpin violated Canon 1 and Rule 1.01 of the CPR by knowingly
listing him as a stockholder, Chairman of the Board and President of LCI when she knew that he had already
resigned and had never held any share nor was he elected as chairperson of the BOD or been President of
LCI. He also never received any notice of meeting or agenda where his appointment as Chairman would be
taken up. He has never accepted any appointment as Chairman and President of LCI.
IBP recommend her temporary suspension.
Issue:
WON Atty. Limpin violated Canon 1 of the CPR.
Ruling:
Yes.
Members of the bar are reminded that their first duty is to comply with the rules of procedure, rather than
seek exceptions as loopholes.19 A lawyer who assists a client in a dishonest scheme or who connives in
violating the law commits an act which justifies disciplinary action against the lawyer.20
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Grounds for such administrative action against a lawyer may be found in Section 27, 22 Rule 138 of the Rules
of Court. Among these are (1) the use of any deceit, malpractice, or other gross misconduct in such office
and (2) any violation of the oath which he is required to take before the admission to practice.
After going through the submissions and stipulations of the parties, we agree with the IBP that there is no
indication that Guarin held any share to the corporation and that he is therefore ineligible to hold a seat in
the BOD and be the president of the company.23 It is undisputed that Atty. Limpin filed and certified that
Guarin was a stockholder of LCI in the GIS. While she posits that she had made the same in good faith, her
certification also contained a stipulation that she made a due verification of the statements contained
therein. That Atty. Limpin believed that Guarin would sign a Deed of Assignment is inconsequential: he
never signed the instrument. We also note that there was no submission which would support the allegation
that Guarin was in fact a stockholder. We thus find that in filing a GIS that contained false information, Atty.
Limpin committed an infraction which did not conform to her oath as a lawyer in accord with Canon 1 and
Rule 1.01 of the CPR.
We also agree with the IBP that in allowing herself to be swayed by the business practice of having Mr. de
los Angeles appoint the members of the BOD and officers of the corporation despite the rules enunciated in
the Corporation Code with respect to the election of such officers, Atty. Limpin has transgressed Rule 1.02 of
the CPR.

DR. ELMAR O. PEREZ, Complainant, v. ATTY. TRISTAN A. CATINDIG AND ATTY. KAREN E.
BAYDO, Respondents.
DECISION
The Facts
Dr. Perez and Atty. Catindig had been friends since the mid-1960s when they were both students at the
University of the Philippines, but they lost touch after their graduation. Sometime in 1983, the paths of Atty.
Catindig and Dr. Perez again crossed. It was at that time that Atty. Catindig started to court Dr. Perez. 2
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Atty. Catindig admitted to Dr. Perez that he was already wed to Lily Corazon Gomez (Gomez). But latter,
Atty. Catindig obtained a divorce decree in Dominican Republic.
Thus, on July 14, 1984, Atty. Catindig married Dr. Perez in the State of Virginia in the United States of
America (USA). Their union was blessed with a child.6
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Years later, Dr. Perez came to know that her marriage to Atty. Catindig is a nullity since the divorce decree
that was obtained from the Dominican Republic by the latter and Gomez is not recognized by Philippine laws.
Sometime in 2001, Dr. Perez received an anonymous letter9 in the mail informing her of Atty. Catindigs
scandalous affair with Atty. Baydo, and that sometime later, she came upon a love letter 10 written and signed
by Atty. Catindig for Atty. Baydo. In the said letter, Atty. Catindig professed his love to Atty. Baydo,
promising to marry her once his impediment is removed.
On October 31, 2001, Atty. Catindig abandoned Dr. Perez and their son; he moved to an upscale
condominium in Salcedo Village, Makati City where Atty. Baydo was frequently seen. 12
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The Issue
The issue in this case is whether the respondents committed gross immorality, which would warrant their
disbarment.
Ruling of the Court
The Code of Professional Responsibility provides:
Rule 1.01 A lawyer shall not engage in unlawful, dishonest, immoral or deceitful conduct.
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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.
Rule 7.03 A lawyer shall not engage in conduct that adversely reflects on his fitness to practice law, nor
should he, whether in public or private life, behave in a scandalous manner to the discredit of the legal
profession.
In Arnobit v. Atty. Arnobit,33 the Court held:
[T]he requirement of good moral character is of much greater import, as far as the general public is
concerned, than the possession of legal learning. Good moral character is not only a condition precedent for
admission to the legal profession, but it must also remain intact in order to maintain ones good standing in
that exclusive and honored fraternity. Good moral character is more than just the absence of bad character.
Such character expresses itself in the will to do the unpleasant thing if it is right and the resolve not to do
the pleasant thing if it is wrong. This must be so because vast interests are committed to his care; he is the
recipient of unbounded trust and confidence; he deals with his clients property, reputation, his life, his
all.34 (Citation omitted)
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Contracting a marriage during the subsistence of a previous one amounts to a grossly immoral
conduct.