REPUBLIC OF THE PHILIPPINES
MA. CELIA C. SUAREZ,
-versus- A. C NO. ___
Petitioner respectfully states:
This is a petition for disbarment against a member of the Philippine Bar instituted in accordance with Section 1, Rule 139-B of the Rules of Court which states:
“SECTION 1. How Instituted. —
Proceedings for the disbarment, stispension, or discipline of attorneys may be taken by the Supreme Court motu proprio, or by the Integrated Bar of the Philippines (IBP) upon the verified complaint of any person. The complaint facts complained, of and shall be supported by affidavits of persons having personal knowledge of the facts therein alleged and/or by such documents as may substantiate said facts. xxx”
Invoking the standards of morality and integrity by which members of the bar are required to comply with, the Petitioner comes to the Honorable Supreme Court to seek the mantle of justice in cleansing the Philippine Bar of a lawyer whose only aim in practicing law seems to focus on immorality, graft and corruption and most of all embarrassing the highest post in the land, that is, the Philippine presidency. In this respect, this Honorable Court should expunge from the roll of attorneys and the ranks of its officers such unscrupulous member of the Integrated Bar.
1. Petitioner, Ma. Celia C. Suarez, is of legal age, single, Filipino and with postal address at xxxxxxxx Parc Chateau Condominium, Ortigas Center, Pasig City. She is also known as Virginia Suarez, the same being her baptismal name. She began to use the name of Ma. Celia Suarez only when a problem crop up in her application for a U.S. Visa, i.e. her name Virginia C. Suarez was unregistered.
2. Respondent Jose Miguel Arroyo, is a member of the Philippine Bar, of legal age, and currently the Republic of the Philippines’ First Gentleman (FG) being married to the President of the Republic of the Philippines, Gloria Macapagal-ArrOYO (GMA) and residing officially at Malacañang Palace, San Miguel, Manila where he may be served with summons and this Honorable Court’s processes.
MATERIAL ALLEGATIONS IN SUPPORT FOR
THE PETITION FOR DISBARMENT
3. Petitioner invokes the following provisions of the Code of professional Responsibility, which state:“Rule 1.01 - A lawyer shall not engage in unlawful, dishonest, immoral or deceitful conduct.”
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, .1 — - .t...i~...
life, behave in a scandalous manner to the discredit of the legal profession.”
as having been violated by the Respondent and in support thereof states:
A. ACTS OF IMMORALITY
I. INITIAL ENCOUNTER
4. Petitioner met Respondent sometime in the year 1976 or 1977 through her friend xxxxxxxx who happened to have Respondent as one of her clients. Petitioner went along with xxxxxxxx in one of the latter’s business meetings with Respondent at 801 JMT Building along Ayala Avenue, Makati where Respondent h&d office.
4.1 Respondent was then a partner at the Arroyo Barin and Ortile Law Offices.
4.2 The Barin in the firm name refers to Atty. Barin who is the husband of the present Securities and Exchange Commission Chairman Fe Barin.~
4.3 Petitioner was a blooming and vibrant 26 year-old lady at that time; Respondent was about ten (10) years older.
5. Petitioner and Pompons hopped into the elevator of the JMT Building and by chance Respondent took said elevator also. Respondent was obviously attracted to petitioner as he lecherously stared at petitioner in the eyes. FG was staring seductively at the petitioner.
6. After having been introduced to each other, V Respondent pursued the petitioner romantically. He lavished the petitioner with flowers and gifts and bombarded her with calls. Thereafter, they dated almost every day.
7. After two (2)or three (3) months of constant dating, they became steady lovers.
7.1 During all this time, Respondent misrepresented himself and deceived petitioner into believing that he (Respondent) was already separated from his spouse, GMA.
II GHOST EMPLOYEE
8. In order to hide their amorous relationship, Respondent made it appear that petitioner was working in his law office. The truth of the matter being that petitioner did not lift a finger in Respondent Arroyo’s office. Years later, this would be the same set up Respondent devised for Vicky Toh. In support of this allegation a copy of the Affidavit executed b~ is attached hereto as Annex “A’
8.1 Eventually, the amorous relationship became public knowledge such that it became known in the whole JMT Building from the lowest employee to the law partners~ Respondent flaunted with this immoral conduct and bragged about his relationship with the petitioner.
8.2 The brother and xxxxxxxx espondent, Iggy and xxxxxxxx and the xxxxxxxx side of the xxxxxxxx family even knew about the romance and relationship.
8.3 subsequently, Respondent even devised a set up wherein every time GMA visits him in JMT Building, the security guard at the reception area would warn petitioner of the same so she could make herself scarce.
8.4 Proof that petitioner “held office” at 801 JMT~ Building, Ayala Avenue is a Notice of Premium Due from The Philippine American Life Insurance Company addressed to petitioner at said office. A copy of said notice is attached hereto and made an integral part hereof as Annex “B”.
8.5 Further proof, is a photograph of the petitioner sitting on the lap of Respondent, with the latter’s polo unbuttoned and both happily enjoying each other’s company at the law office which is attached hereto and made an integral part hereof as Annex “C”.
8,6 In fact, right in front of Respondent’s table at the law office was a sofa where Respondent and petitioner would occasionally have carnal knowledge.
9. In many instances, what the petitioner and Respondent did, instead of working, was to engage in drinking sessions every night. They would have this drinking sessions with Respondent’s partners and cousins. Respondent would broadcast to them that petitioner was her “favorita” and would call GMA an “igorota”.
9.1 Respondent would always express that his being a drunkard is to forget GMA, to somehow erase from his memory the fact that he was married to GMA.
10. Eventually, Respondent made petitioner the president of one of his family’s companies, Harmoney Realty and Development Corporation.
10.1 Respondent’s family owns Harmoney Realty as evidenced by Assignments of Subscription between Emmanuel C. Alcantara and Lourdes T. de Arroyo, Inc.; and Evangeline de Silva and Lourdes T. de Arroyo, Inc., both dated 27 January 1981. Lourdes T. de Arroyo, Inc. was represented by Respondent. Copies of said contracts are attached hereto and made integral parts hereof as Annexes “D” and “E”.
10.2 Proof that petitioner was made President of Harmoney Realty and Development Corporation is a letter addressed to her as President of Harmoney Realty and Development Corporation by S. S. Dario and Company, Inc. dated 27 November 1981, copy of which is attached hereto and made an integral part hereof as Annex “F”.
10.3 Harmoney Realty and Development Corporation held office at the 3td floor, LTA Building, Perea St. Legaspi Village, Makati.