* "First Boor" refers to the title editorial of the Philippine Daily Inquirer on March 2007 entitled 'First Boor,' referring to Jose Miguel Arroyo after he challenged to a fight a defense lawyer who was cross-examining him during the trial of one of the several libel cases he has filed against the media. The full editorial is located here
III. COHABITATION
11. Respondent housed petitioner first in BF Homes, ~ Parañaque. A certain’ :~ and a ~ who
worked with Country Bankers Insurance Company are only some of those who knew that’ and petitioner made a “love nest” of said house.
12. In 1980, Respondent and petitioner transferred to Greenbelt Mansion, Perea St., Legaspi Village, Makati. They rented Room xxxxxxxx thereof.
12.1 Greenbelt Mansion is just in front of LTA Building which is owned by the family of Respondent.
12,2 Proof of the petitioner and Respondent’s cohabitation thereat are the following:
12.2.1 Rentacolor Philippines, Inc.contract for the lease of television unit addressed to the petitioner at said address and signed by Respondent as surety dated 17 February 1981 and a demand letter from Rentacolor Philippines, Inc. dated 12 March 1982. Copies of the same are attached hereto and made integral parts hereof as Annexes “H” and “I”.
12.2.2 Statement from Wellington Investment & Manufacturing Corporation Greenbelt Mansion Realty Division dated 21 December 1981 and Provisional Receipt from the same corporation dated 29 December 1981 addressed to the; ~ petitioner. Copies of said contracts are attached hereto and made integral parts hereof as Annexes “Y’ and “K”.
12.3 The r. at said house, ~ can also attest to the foregoing as she in fact has prepared an affidavit to that effect. A copy of said affidavit is attached hereto and made an integral part hereof as Annex “L”.
13. Respondent was a regular fixture of the house. Respondent practically lived there as he was there every single day and night. He ate there. He slept there. He had his clothes washed there. It even came to a point that Respondent’s law office staff would bring documents there for his signature since he was always there. C See Annex “A” hereof)
13.1 Petitioner and Respondent would make love everyday, sometimes even thrice a day.
13.3 Unknown to GMA and her children, Respondent rings petitioner when everybody is out and brings her to their La Vista residence in Quezon City.
13.4 Likewise, Respondent’s purported joggings in the morning is just a ruse for him to be able to meet petitioner in ~L house inside the subdivision also ~:,~‘fts a mutual friend of ~ ~and the petitioner, she also held office ~t the JMT Building. The affidavit of s attached hereto as Annex
IV. PROMISE OF MARRIAGE
14. Well settled is the rule that when a member of the Bar seduces a woman to have carnal knowledge with her on the basis of misrepresentation that he is going to marry her is deemed a grossly immoral act. (Almirez vs. Lopez, G.R. Adm. Case No. 481, 28 February 1969, 27SCRA 169). In fact, the acts of Respondent are so corrupt and false and so unprincipled or disgraceful to a reprehensible degree which will justify his disbarment! This is reflected in the that all throughout their relationship, Respondent would always promise to marry petitioner declaring that she was already separated from GMA. The petitioner readily believe the respondent the latter being a lawyer at that. It was only after a while that petitioner came to know that Respondent Arroyo tricked, deceived and used her in order that she would continue in allowing him to 1have carnal knowledge with her.
15. Respondent told petitio~ier that he was just forced to marry GMA inasmuch as she was the then incumbent President’s daughter. Respondent narrated that he was somewhat duped in marrying GMA as he was told that the latter has a throat cancer which is life threatening. This ruse is clearly so unprincipled and so reprehensible that the Office of the President of the Republic of the Philippines would be made the object of mockery should Respondent be allowed to continue spreading this gospel so to speak, in order that he may have carnal knowledge with women other than his legal wife.
15.1 No less than Respondent’s xxxxxxxx was used by Respondent to confirm the throat cancer story aforementioned, such that this convinced petitioner of the gospel truth of what Respondent was espousing.
15.2 It was because of this misrepresentation that petitioner held on to Respondent Arroyo’s promises.
16. Coupled with this is the treatment accorded by xxxxxxxx to petitioner as the former openly accepted her as the other woman in the life of her xxxxxxxx. xxxxxxxx did not like GMA as she was allegedly just forced upon Respondent.
16.1 In fact, xxxxxxxx always picked up petitioner for shopping here and abroad. Petitioner can sincerely say that she is well-loved and liked by xxxxxxxx.
16.2 Respondent even.exerted efforts to bring his children, Mikee and Lull, and petitioner closer. Petitioner went shopping with Respondent’s children, introducing her as his secretary. Mikee was around 7 or 8 years old then. Lull on the other hand became very fond of petitioner.
V~ GIFTS OF “LOVE”
17. During the course of their illicit relations, / Respondent would lavish petitioner with gifts, e.g., the giving of a 1978 Colt Gallant Station WagOn in 1982 as a token of love and subsequently another vehicle of later model.
17.1 Respondent’s ownership and transfer of / ownership to the petitioner is evidenced by a Deed of Sale (obviously simulated) dated 27 January 1982, copy of which is attached hereto and made an integral part hereof as Annex “N”.
18. Petitioner was likewise a constant companion of Respondent in his travels abroad. Sometimes petitioner even traveled with some of Respondent’s relatives. When Respondent cannot come with petitioner, Respondent would treat petitioner’s sister, xxxxxxxx, to go around the world with petitioner. Some of the places visited were:
18.1 Hong Kong
18.2 San Francisco, California, USA
18.2.1 Photographs of petitioner and FG in the Japanese Garden in San Francisco, California are attached hereto and made integral parts hereof as Annexes “0”, et seq.
18.2.2 Recent photograph of Respondent and petitioner’s relatives in San Francisco, California is attached hereto and made an integral part hereof as Annex “P”.
18.3 Oakland, California, USA
18.3.1 Photographs of petitioner and FG in are attached hereto and made integral parts hereof as Annexes “Q”, et seq.
18.4 Vancouver, Canada
18.5 Toronto, Canada
18.6.1 Ph~tograph of petitioner and respondent in Canada is attached hereto and made an integral part hereof as Annex “R”.
18.7 Petitioner and Respondent likewise went to Bagulo. Photographs of the same are attached hereto and made integral parts hereof as Annexes “S” et seq.
18.7.1 Photograph of the petitioner and Respondent in a beach is attached hereto and made an integral part hereof as Annex “T”.
VI. BETRAYAL BY RESPONDENT
19. Sometime in the mid-1980’s, the relationship turned sour when petitioner discovered Respondent’s secret relationship with Vicky Toh (Vicky).
20. When petitioner could not take it any longer, she entertained other suitors.
20.1 When Respondent got wind of the same, he became very angry and confronted the petitioner.
20.2 Petitioner was the aggrieved party. However, Respondent would like to make it appear that it was the petitioner who betrayed him.
20.3 During a particular confrontation, knowing that she is being made a fool by Respondent, petitioner threw the Ateneo College ring given to her by Respondent to the latter’s face. Petitioner could no longer bear the hurts and betrayal upon her by Respondent.
21.~ Though Respondent was adamant, Petitioner resisted all of Respondent’s attempt to win her back. In one evening, Respondent went to petitioner’s house in Pasig City.
21.1 Respondent was very, very drunk, crying, crawling and vomiting. Respondent begged for petitioner’s mother to help him win back the petitioner.
21.2 Respondent’s theatrics was not able to persuade petitioner’s mother. Ultimately, Respondent fell asleep in his car.
21.3 Suddenly, GMA arrived to pick up petitioner’s mother demanding that petitioner leave Respondent alone.
21.4 Petitioner’s mother retorted that GMA should take care of her husband if she does not want it to loiter around or else she would sue them for trespassing.
22. Respondent still tried to woo her to no avail, as petitioner knew that Vicky Toh had already replaced her in the office and in his illicit sexual life.
VIII 2001 MEETINGS
23. Petitioner had the chance to talk via a phone call to Respondent again sometime on 2001. The purpose of petitioner’s call was only to congratulate Respondent for the victory of his wife. However, because of their previous relationship, Respondent invited petitioner to have breakfast at the Café Rizal which is in Greenbelt 1 to which the petitioner acceded~
23.1 Respondent hugged the petitioner, oblivious of the prying eyes of the public. Days later, Respondent tried to court petitioner again.
23.2 Petitioner however would not have anymore of Respondent’s bravado because he admitted that he could not leave Vicky Toh because of the latter’s help and deyotion to him when he was financially down especially with covering up for his ownership of the “Pidal” checking account.
24. Petitioner was prevailed upon to meet Respondent again. The dinner was at Respondent’s office and lasted from 7-12 midnight.
24.1 Petitioner was not able to control Respondent’s advances. He kissed petitioner behind her ears, caressing and then mashing her breasts with his two hands.
24.2 Respondent however was not contented with the same. He pulled petitioner and had her seat on his lap while continuously mashing her breast and kissing her behind the ears.
24.3 Respondent was doing the above while his staff were just outside the door. The staff includes one one of his xxxxxxxx whose affidavit is attached hereto as Annex “U”.
24.4 PhotographS~ of the petitioner and Respondent in the latter’s office at LTA Builthng, Perea St. Makati, are attached hereto and made integral parts hereof as Annexes “V”, et seq. The photograph was taken during another occasion.
VIII. 2002 MEETING
25. On 07 March 2002, Respondent came to petitioner’s house at xxxxxxxx Acropolis Village, Libis, Quezon City’ to have dinner. ~t:~ :‘~ ~~~f-~accompanied him (see Annex”A” herein)
251 Respondent’S arrival caused alarm as the security guards fronting the GreenmeadOWS side were asked to open the gate through a vehicle megaphone.
25.2 Durjng the dinner, petitioner angrily confronted~ReSPOfldeflt Arroyo about her discovery that the latter had bought.a house inside Acropolis for his .~ alleged new girfriend, movie starlet xxxxxxxx.
25.3 Respondent corrected petitioner and told her that said starlet was actually tt~e girlfriend of Mikee Arroyo, his son.
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25.4 A photogra~h of the above visit is attached hereto and made an integral part hereof as Annex “V’,,’1
