Spouses David and Marisa Williams v. Atty. Rudy T. Enriquez February 27, 2006 Facts: Atty.

Enriquez, a retired judge, stands charged with unlawful, dishonest, immoral and deceitful acts in violation of the Code of Professional Responsibility and the Canons of Professional Ethics, and with conduct unbecoming an attorney. filed by the petitioner. Marisa Williams bought the lot subject of the controversy, a TCT was then issued in her favor, stating that she is Filipino, married to David W. Williams, an American citizen. Respondent charged her with falsification of public documents before the Office of the City Prosecutor of Dumaguete City, declaring that her act of marrying her husband was equivalent to renouncing her citizenship. He also doggedly attempts to show that the 1987 Constitution supports his position Enriquez cited outdated materials in his complaint - affidavit, to argue that Marisa had lost her filipino citizenship when she married an american and is this prohibited from owning land in the ph - making her guilty of falsification in the deed to buy property in Negros oriental. The complaint for his disbarment was a mere tactic to divert attention to the criminal charges against her. The case was brought to Integrated Bar of the Philippines. - respondent only appeared in P's position paper: respondent had maliciously and knowingly fabricated cases against them and his acts were mere form of extortion. Respondent maintained that complainant Marisa Williams was no longer a citizen of the Republic of the Philippines as a result of her marriage to David Williams. Ruling: There is no evidence shown by respondent that complainant has renounced her Filipino citizenship except her Certificate of Marriage, which does not show that she has automatically acquired her husbands citizenship upon her marriage to him. The cases cited by respondent are not applicable in this case as it is clear that they refer to aliens acquiring lands in the Philippines. Lawyers must keep themselves abreast of legal developments. He must acquaint himself at least with the newly promulgated laws, the recent decisions of the Supreme Court and of the significant decisions of the Court of Appeals. There are other executive orders, administrative circulars, regulations and other rules promulgated by other competent authorities engaged in the administration of justice. The lawyers life is one of continuous and laborious study, otherwise, his skill and knowledge of the law and related disciplines will lag behind and become obscure due to obsoleteness (Canon 5, Code of Professional Responsibility.) Indeed when the law is so elementary, not to know it constitutes gross ignorance, but since the respondent was a retired judge it is incumbent upon him to be abreast with the latest rulings of the court on the issues and legal problems confronting a client - he misconstrued the constitution which is the basic law of the land. The power to disbar or suspend must be exercised with great caution and only for a clear case of misconduct that seriously affects the standing and character of a lawyer as an officer of the Court and member of the bar. The penalty of reprimand by the IBP commission on bar discipline will suffice with it having been his first infraction

WHEREFORE, for gross ignorance of the law, Atty. Rudy T. Enriquez is REPRIMANDED and ADVISED to carefully study the opinions he may give to his clients. He is STERNLY WARNED that a repetition of a similar act shall be dealt with more severely.