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Joselano Guevarra


Atty. Jose Emmanuel Eala


Joselano Guevarra filed a complaint for disbarment before the Integrated Bar of the Philippines (IBP)
Committee on Bar Discipline (CBD) against Atty. Jose Emmanuel Eala a.k.a. Noli Eala (respondent) for
grossly immoral conduct and violation of the lawyers oath.

The complainant first met respondent in January 2000 when his (complainants) then- fiance Irene
Moje introduced respondent Nolu Eala to him as her friend who was married to Mary Ann Tantaco with
whom he had three children.

After his marriage to Irene, complainant noticed that Irene had been receiving from respondent
cellphone calls, as well as messages some of which real I love you, I miss you, or Meet you at
Megamall. He also noticed that Irene habitually went home vey late at night or early in the morning of
the following day, and sometimes did not go home from work. Complainant also had seen Irene and
respondent together in two occasions. On the second occasion, he confronted them following which
Irene abandoned the conjugal house.

The complainant later found out in the masters bedroom, a folded card bearing the wods I love you
on its face, dated October 7, 2000, the day of hi wedding to Irene. It was also revealed that Irene gave
birth to a girl in 2002, naming respondent in the Certificate of Live Birth as the girls father.

In the respondents answer to complainants allegations, he specifically denies having ever flaunted an
adulterous relationship with Irene, that their relationship was low profile and known only to the
immediate members of their respective families. He also said that his special relationship with Irene is
neither under scandalous circumstances nor tantamount to grossly immoral conduct as would be a
ground for disbarment.

ISSUE: Whether or not respondent be disbarred from the practice of law


Yes, the respondent should be disbarred from the practice of law as it involves the relationship between
a married lawyer and a married woman who is not his spouse even though the affair was carried out

While it was been held in disbarment cases that the mere fact of sexual relations between two
consenting adults is not sufficient an administrative sanction for such illicit behavior, it is not so with
respect to betrayals of the marital vow of fidelity.

Respondent also violated the lawyers oath he took before practicing law, Rule 1.01 of Canon 1 of the
Code of Professional Responsibility which prescribes a lawyer from engaging in unlawful, dishonest,
immoral, or deceitful conduct. And Rule .03 of Canon 7 of the same code which prescribes a lawyer
from engaging in any conduct that adversely reflects on his fitness to practice law.