Republic of the Philippines SUPREME COURT Metro Manila
MARIA STA. ANA Plaintiff
Disbarment Case: for: Grossly Immoral Conduct
,
-versus-
ATTY. JUAN DELA CRUZ Defendant, x-----------------------------------------------------x DISBARMNET COMPLAINT COMES NOW the Plaintiff, by undersigned counsel, and unto this Honorable Court, most respectfully alleges that: 1.
Plaintiff an 18 years of age, Filipino, single and a resident of #33, Sacal St. Lapasan, Cagayan de Oro City, Philippines. For purposes of this action, Plaintiff may be served with copies of our notices and orders of the Honorable Court at the office address of the undersigned counsel indicated below;
2.
Defendant is also of legal age, Filipino, and for purposes of this action, he may be served with summons and other processes of this Honorable Court at his residence and post-office address at #21, Palad St, Gusa, Cagayan de Oro city, Philippines;
3.
That on or about March 14, 2012, at 10: 45 in the morning, at the office of Atty. Juan Dela Cruz, located at Nazareth, Cagayan de Oro City, the said accused did then with force, intimidation, threats, with lewd and unchaste designs, willfully, unlawfully, and feloniously take and carry away a virgin against the will of the plaintiff with abuse of confidence and authority to promote and facilitate the prostitution and corruption of the plaintiff, for the purpose of satisfying the carnal lust of others;
4.
Hereto attached the Medical Certificate of MARIA STA.ANA. STA.ANA. to form as an integral part of this complaint.
PRAYER WHEREFORE, it is most respectfully prayed that, after due hearing, judgment be rendered in favor of the plaintiffs: a) Ordering the Defendant, to be disbarred to his profession as lawyer; b) Ordering the Defendant, to pay plaintiff moral damages at the amount of one million pesos; Other reliefs just and equitable under the premises are likewise prayed for. Cagayan de Oro City, Philippines, July 16, 2011.
ATTY. REYCARTE M. NAMBATAC Attorney’s Roll No. xxxxx IBP No. xxxxx (01-09-2012) PTR No. xxxxxxx (01-09-2012
VERIFICATION AND CERTIFICATION Republic of the Philippines) Cagayan de Oro City ) S.S. x------------------------------------x I, MARIA STA. ANA, an 18 years of age , Filipino, single, and a resident of #33,Sacal st. Lapasan, Cagayan de Oro City, Philippines, after been duly sworn in accordance with law, state: That I ‘am the Plaintiff in this case; That the facts alleged therein are true and correct of my own knowledge; That aside from the instant case, I have not filed any other case in the Supreme Court, nor in the Court of Appeals or in any other court involving the same subject matter; That I do not know of any other case involving the same subject matter and should I learn of any I shall inform the Honorable Court within 5 days from such knowledge; That I’ am executing this Disbarment Complaint in connection with the requirement of the Supreme Court on Non-Forum Shopping. IN WITNESS WHEREOF, I have hereunto set my hands this 16 th day of July, 2012 at Cagayan de Oro City, Philippines.
MARIA STA.ANA Affiant SUBSCRIBED AND SWORN to before me this 16 th day of July, 2012 at Cagayan de Oro City, Philippines.
ATTY. REYCARTE M. NAMBATAC Attorney’s Roll No. 52525 IBP No. 12345 (01-09-2010) PTR No. 09876 (01-09-2010) MCLE No. III-82889 Doc. No. ______; Page No. ______; Book No. ______; Series of ______;
COPY FURNISHED: ATTY. JUAN DELA CRUZ Defendant Rodelsa Hall, Kauswagan, Cagayan de Oro City
