PART II LEGAL ETHICS

II.1K – ATTY. ROY B. ECRAELA vs. ATTY. IAN RAYMOND A. PANGALANGAN

FACTS:

1. Complainant and respondent were peers/barkada in UP College of Law who both passed
the bar at the same time in 1991 and both registered with IBP quezon City
2. Respondent was previously married to Shiela P. Jardiolin with whom he had 3 children.
3. During the course of their marriage, it is alleged by the complainant that the respondent
had a series of adulterous and illicit relationships with women, some of whom were
married at the time. These alleged relationships involved AAA, a spouse of a colleague at
the college of law in 1991-992; BBB, single; CCC and DDD at the same time in 2000 to 2002;
and EEE who is related to the complainant in May 2004 until the filing of the case.
4. Sometime during the period 1998 – 2000 when respondent was working as a lawyer with
the Office of the Government Corporate Counsel (OGCC), represented the interest of
Manila International Airport Authority (MIAA) in a case against Kendrick Development
Corporation (KDC).
5. Complainant alleges that responded conspired with and assisted KDC in the said case
sabotaging the MIAA’s case. Respondent attempted to bribe a Solicitor at the OSG in
exchange for the dismissal of the case with a car.
6. The respondent was summoned to a senate inquiry regarding the MIAA case, wherein the
Senate Blue Ribbon and Justice & Human Rights Committees recommended the filing of a
graft case by the ombudsman and disbarment of the respondent.
7. The respondent attempted to conceal the car offered to the OSG solicitor by asking the
complainant’s parents to park the car in their Cainta residence for an indefinite period.
8. As an educator in Manuel L. Quezon University, San Sebastian College, College of St.
Benilde, and Maryknoll College, respondent induced his male students to engage in
"nocturnal preoccupations" and entertained the romantic gestures of his female students
in exchange for passing grades.
9. Complainant presented several witnesses who corroborated all his allegations.
10. In his reply , respondent did not refute the allegations, only the procedural and substantive
infirmities of the petition.
IBP Findings: Found respondent guilty gross misconduct affecting his standing and moral character
as an oDcer of the court and member of the bar and a suspension of 2 years
IBP-BOG: Adopted and approved with modification, instead of suspension, disbarment was
recommended.
Violated Law/canon : Article XV of the 1987 Constitution, Section 2, Rule 1.01 of Canon 1, Rule 7.03
of Canon 7, and Rule 10.01 and 10.02 of Canon 10 of the Code of Professional Responsibility, and
the Lawyer's Oath
ISSUES:
1. WON the respondent committed gross immoral conduct, which would warrant his
disbarment? YES.
RULING:
As officers of the court, lawyers must not only in fact be of good mora character but must also be
seen to be of good moral character and leading lives in accordance with the highest moral standards
of the community. A member of the bar and an officer of the court is not only required to refrain
from adulterous relationships or keeping a mistress but must also so behave himself as to avoid
scandalizing the public by creating the impression that he is flouting those moral standards. The
moral delinquency that affects the fitness of a member of the bar to continue as such includes
conduct that outrages the generally accepted moral standards of the community, conduct for
instance, which makes 'a mockery of the inviolable social institution of marriage.'" In various cases,
the Court has held that disbarment is warranted when lawyer abandons his lawful wife and
maintains an illicit relationship with another woman who has borne him a child.
Instead of refuting these claims, respondent merely pointed out in his Answer that complainant
failed to adduce additional evidence, and that complainant's statements were merely self-serving
averments. In all, Atty. Pangalangan displayed deplorable arrogance by making a mockery

SALAMIDA, CHIIC A. 1
 PART II LEGAL ETHICS

out of the institution of marriage, and taking advantage of his legal skills by attacking the Petition
through technicalities and refusing to participate in the proceedings. His actions showed that he
lacked the degree of morality required of him as a member of the bar, thus warranting the penalty
of DISBARMENT.

SALAMIDA, CHIIC A. 2