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In re: Peralta, 101 Phil. 313

A case digest of In re: Peralta, 101 Phil. 313:

Case Title: In Re Charges of LILIAN F. VILLASANTA for Immorality, vs. HILARION M. PERALTA

Key Facts:

  • Marriage History: Hilarion M. Peralta was married to Rizalina E. Valdez in 1939. He subsequently began a relationship with Lilian F. Villasanta in 1951.
  • Fake Marriage: Peralta convinced Villasanta to sign a blank marriage contract, which he then had falsely notarized by authorities, making it appear like a real marriage had taken place.
  • Bigamous Relationship: Peralta and Villasanta lived together as husband and wife while Peralta's first marriage remained valid.
  • Religious Ceremony: The couple later had a religious wedding ceremony performed, even though their union was not legally recognized.
  • Discovery and Criminal Charges: Villasanta discovered Peralta's prior marriage and filed criminal charges against him under Article 350 of the Revised Penal Code (which relates to bigamy). Peralta was found guilty at trial, and the conviction was upheld on appeal.

The Disbarment Issue:

The In re: Peralta case centers on whether Peralta should be admitted to the Philippine bar. He had passed the bar exam, but Villasanta filed this separate complaint arguing that his actions demonstrated a lack of good moral character.

Supreme Court Ruling:

The Philippine Supreme Court ruled that Peralta's actions were contrary to:

  • Honesty: He engaged in deception and fraud.
  • Justice: He violated marriage laws and undermined the institution.
  • Decency: His actions were socially unacceptable.
  • Morality: He demonstrated poor moral judgment throughout.

Due to the conviction and the finding of lacking good moral character, Peralta was disqualified from being admitted to the bar.

Significance of the Case:

The case underscores the high ethical standards required for admission to the legal profession in the Philippines. It sends a strong message that lawyers must uphold high moral standards in their personal lives as well as their professional ones.

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Location: Davao City, Davao del Sur, Philippines

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