Broken vows

This case involves Carlo, a lawyer who was eventually disbarred for his obvious disregard for the sanctity of marriage and his unethical conduct.

Around April 1953, while still a law student, Carlo began courting Mila, a young woman whose education reached only first year of high school. By July 1954, Mila accepted his proposal of marriage. In November of the same year, the couple secured their residence certificates and went to the local Civil Registrar’s Office to apply for a marriage license. Inside the office, they signed documents, after which the registrar asked if they were willing to marry each other, and both answered yes.

Then, they proceeded to another room where a female doctor conducted a blood test. Upon leaving, Carlo told Mila that they were already legally married and suggested he introduce her to his uncle. However, on their way, they entered what Mila later discovered was a hotel. After registering, Carlo persuaded Mila to engage in sexual relations, assuring her that they were already husband and wife. Trusting him, Mila gave in.

Three days later, Carlo showed Mila the blood test report, pointing out that the word “bride” was written under her occupation, using this as supposed proof of their marriage. Believing this, Mila continued meeting him, and they engaged in sexual relations regularly over the next few months in different hotels.

In January 1955, Mila questioned why they were not yet living together as husband and wife. Carlo responded that he was still waiting for his Bar exam results. After passing, he even showed her his certificate as a gesture of affection. Mila then urged him to formalize their union with her family, and Carlo agreed.

In March 1955, Carlo spoke with Mila’s father, who suggested a church wedding since both were Catholics. Preparations were made, and the wedding was scheduled for May 15, 1955. However, before the date, Mila received a letter from Carlo withdrawing from their agreement. Upon reviewing the documents, her father discovered that no civil marriage had actually taken place. Mila then revealed that she was pregnant. On June 9, 1955, Carlo married another woman, while Mila gave birth to their child on Aug, 4, 1955.

Mila subsequently filed a complaint before the Supreme Court, accusing Carlo of immorality and seeking his disbarment. Carlo admitted their relationship and acknowledged the child but denied deceiving Mila, claiming that she willingly consented to their intimacy.

The Court found his defense unconvincing. It concluded that Carlo never intended to honor his promise of marriage and had deliberately misled Mila to satisfy his personal desires. Taking advantage of her limited education and lack of understanding of legal procedures, he manipulated her trust.

As a lawyer, Carlo was expected to uphold the highest standards of morality and integrity. His actions fell far below these standards. Should Carlo be disbarred?

Yes. Carlo’s defense cannot be believed. The truth is that all along he never intended to redeem Mila’s honor. He had lured her into believing that they had been civilly married to satisfy his own desires. He himself admits that what prompted him to offer and propose marriage to her was to satisfy such desire.

On the other hand, Mila has not gone far in educational attainment, having reached only first year high school, and does not have the slightest idea of a legal and valid marriage. Thus, she became an easy victim of a man like Carlo, a lawyer who knows the intricacies of the law and how to escape from the consequences of his actions.

Carlo has not maintained the highest degree of morality and integrity which, at all times, is expected of and must be possessed by members of the Bar. He is therefore disbarred from the practice of law and his name in the roll of attorneys is stricken out. (Cabrera vs. Agustin, A.C. No 225, Sept. 30, 1959, 106 Phil. 256).

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