Magdalena Arciga vs Segundino Maniwang

A.M. No. 1608 – 106 SCRA 591 – Legal Ethics – Gross Immoral Conduct – Breach of promise to marry

In 1970, when Segundino Maniwang was still a law student, he had a relationship with Magdalena Arciga, then a medical technology student. They started having a sexual relationship in 1971. In 1973, Arciga got pregnant. The two then went to Arciga’s hometown to tell the latter’s parent about the pregnancy. They also made Arciga’s parents believe that they were already married but they would have to have the church wedding in abeyance until Maniwang passes the bar exams. Maniwang secured a copy of his birth certificate in preparation of securing a marriage license.

In 1975, Maniwang passed the bar. But after his oath taking, he stopped communicating with Arciga. Arciga located his whereabouts and there she found out that Maniwang married another woman. Arciga confronted Maniwang’s wife and this irked Maniwang so he inflicted physical injuries upon Arciga.

Arciga then filed a disbarment case against Maniwang grounded on gross immoral conduct. Maniwang admitted that he is the father of Arciga’s child; that he did promise to marry Arciga many times; that he broke those promises because of Arciga’s shady past because apparently Arciga had an illegitimate child even before her son with Maniwang was born.

ISSUE: Whether or not Maniwang should be disbarred.

HELD: No. The Supreme Court ruled that Maniwang’s case is different from the cases of Mortel vs Aspiras and Almirez vs Lopez, and other cases therein cited. Maniwang’s refusal to marry Arciga was not so corrupt nor unprincipled as to warrant disbarment (though not much discussion was provided by the ponente as to why). But the Supreme Court did say that it is difficult to state with precision and to fix an inflexible standard as to what is “grossly immoral conduct” or to specify the moral delinquency and obliquity which render a lawyer unworthy of continuing as a member of the bar. The rule implies that what appears to be unconventional behavior to the straight-laced may not be the immoral conduct that warrants disbarment. Immoral conduct has been defined as “that conduct which is willful, flagrant, or shameless, and which shows a moral indifference to the opinion of the good and respectable members of the community”.

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