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Cambaliza vs. Cristal-Tenorio

1) Anamay Cambaliza filed a complaint against lawyer AnaLiza Cristal-Tenerio, alleging she cooperated in her husband's unauthorized practice of law by listing him as a senior partner on their law office's letterhead and an ID card. 2) The court found Cristal-Tenerio guilty of assisting in unauthorized practice because she allowed her non-lawyer husband to misrepresent himself as a lawyer. 3) Even after Cambaliza withdrew her complaint, the disbarment case could still proceed because such proceedings serve the public interest rather than private grievances.

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54 views1 page

Cambaliza vs. Cristal-Tenorio

1) Anamay Cambaliza filed a complaint against lawyer AnaLiza Cristal-Tenerio, alleging she cooperated in her husband's unauthorized practice of law by listing him as a senior partner on their law office's letterhead and an ID card. 2) The court found Cristal-Tenerio guilty of assisting in unauthorized practice because she allowed her non-lawyer husband to misrepresent himself as a lawyer. 3) Even after Cambaliza withdrew her complaint, the disbarment case could still proceed because such proceedings serve the public interest rather than private grievances.

Uploaded by

Tine Tine
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Anamay Cambaliza vs Atty.

AnaLiza Cristal-Tenerio

ADM Case No. 6890, July 14, 2004

FACTS:

Complainant is the former employee of the respondent in her law office. The former charged the
latter for malpractice or other gross misconduct in the office for cooperating in the illegal practice of law
by her husband. The complainant submitted the following evidences: 1) the letterhead of Cristal-Tenorio
Law Office where the name of Felicisimo Tenorio, Jr., husband of the respondent, is listed as a senior
partner; and 2.) a Sagip Communication Radio’s Group identification card signed by the respondent
where her husband is identified as “Atty. Felicisimo Tenorio, Jr.”. She added that respondent’s husband
even appeared in court hearings. During the investigation of the IBP, complainant filed a Motion to
Withdraw Complaint. Respondent now moved for the dismissal of the case for failure of the
complainant to appear in the said case.

ISSUES:

1. Whether or not respondent is guilty of assisting in the unauthorized practice of law.

2. Whether or not a Motion to Withdraw Complaint in a disbarment proceeding, the case may prosper.

HELD:

1. YES. A lawyer who allows a non-member of the Bar to misrepresent himself as a lawyer and to
practice law is guilty of violating Canon 9 and Rule 9.01 of the Code of Professional Responsibility. Public
policy requires that the practice of law be limited to those individuals found duly qualified in education
and character. The purpose is to protect the public, the court, the client, and the bar from the
incompetence or dishonesty of those unlicensed to practice law and not subject to the disciplinary
control of the Court. It devolves upon a lawyer to see that this purpose is attained, otherwise, the law
makes it a misbehavior on his part subject to disciplinary action, to aid a layman in the unauthorized
practice of law.

2. YES. A case of suspension or disbarment may proceed regardless of interest or lack of interest of
the complainant. Disciplinary proceedings involve no private interest and afford no redress for private
grievance. They are undertaken and prosecuted solely for the public welfare.

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