Altobano-Ruiz vs. Attys. Wilfredo A. Ruiz, Cherry Anne Dela Cruz, and Francisco S. Benedicto, III

A lawyer who systematically evades court orders through false addresses, executes an immoral agreement with a mistress to conceal assets from lawful execution and deprive his minor child of court-ordered support, and abuses his knowledge of the law to circumvent legal processes commits multiple violations of the Code of Professional Responsibility warranting the supreme penalty of disbarment.

Complainant Teodora Altobano-Ruiz is the wife of respondent Atty. Wilfredo A. Ruiz. All three respondents — Atty. Ruiz, Atty. Cherry Anne Dela Cruz, and Atty. Francisco S. Benedicto III — were formerly connected with the Public Attorney's Office (PAO). Atty. Dela Cruz served as complainant's counsel in several cases, while Atty. Benedicto later became Atty. Ruiz's partner in the law firm Benedicto Promento & Ruiz and represented Atty. Ruiz in the petition for declaration of nullity of marriage filed against complainant. The dispute arises from the intersection of a domestic violence case under RA 9262, the ensuing Permanent Protection Order, and the subsequent disbarment complaint alleging that all three respondents conspired through "synchronized acts of harassment" against complainant.

Complainant Teodora Altobano-Ruiz is the wife of respondent Atty. Wilfredo A. Ruiz. On June 4, 2008, she sued Atty. Ruiz before the Regional Trial Court, Branch 162, Pasig City, docketed as JDRC Case No. 7964-SJ, for violation of Republic Act No. 9262 (the Anti-Violence Against Women and Their Children Act), alleging physical violence, emotional stress, and economic abuse by depriving her and their children of support. On September 10, 2008, the RTC granted her prayer for a Permanent Protection Order (PPO), which among other directives ordered Atty. Ruiz to provide support equivalent to 50% of his income from his law office, his partnership at Benedicto Pormento & Ruiz Law Office, and Novastar Consultancy and Trading, Inc., to be withheld and remitted directly to complainant. The PPO became final and executory, with the corresponding entry of judgment issued on March 4, 2013.

Despite the finality of the PPO, Atty. Ruiz refused to provide support. Complainant sought to enforce the PPO, and a writ of execution was issued by the trial court on February 27, 2015. Atty. Ruiz still refused to comply. Worse, on January 16, 2012, he executed a Memorandum of Agreement with Undertaking (MAU) with his mistress, Radelia C. Sy, in which they stipulated that all properties acquired and to be acquired would be temporarily placed under the name of Radelia's son, John Paul C. Sy, evidently to place Atty. Ruiz's earnings beyond the reach of the writ of execution. The MAU also expressly excluded his son Leri Jarren Ruiz from receiving any financial support from their earnings, while allowing Atty. Ruiz visitation rights. Throughout the proceedings, Atty. Ruiz methodically provided the trial court with at least five different addresses, none of which was his true residence, effectively evading service of court processes whenever the court's sheriff attempted to serve the writ of execution.

Atty. Ruiz subsequently filed a petition for declaration of nullity of marriage against complainant, which was eventually granted on December 27, 2016. He also filed three criminal charges for adultery against complainant — one was dismissed for lack of probable cause, while two prospered and resulted in her indictment. In 2012, a warrant of arrest for alleged estafa was issued against complainant just a month before the Bar examination she was set to take.

Respondent Atty. Cherry Anne Dela Cruz was complainant's former counsel in the Anti-VAWC case and allegedly in the nullity and estafa cases. Complainant accused her of mishandling her cases, misrepresenting in open court that she had filed an Answer when she had not, and conspiring with Atty. Ruiz to hide his real whereabouts. Respondent Atty. Francisco S. Benedicto III represented Atty. Ruiz in the nullity case and was his law partner at Benedicto Promento & Ruiz. Complainant alleged that all three respondents conspired through "synchronized acts of harassment" directed against her and her children. The IBP Investigating Commissioner found no conspiracy among the respondents but recommended Atty. Ruiz's disbarment. The IBP-BOG initially affirmed but later reduced the penalty to one-year suspension. The Supreme Court found that Atty. Ruiz had systematically evaded the PPO and writ of execution for at least eight years, used false addresses to deceive the court, and executed the immoral MAU to deprive his child of support.

• Conspiracy among respondents: Complainant alleged that all three respondents conspired through "synchronized acts of harassment" directed against her, consisting mainly of hiding Atty. Ruiz's whereabouts so he could continuously evade giving support and maintain his illicit affair.
• Evasion of support obligation: Complainant charged Atty. Ruiz with systematically evading the PPO and writ of execution to avoid providing support to her and their children, and with executing the MAU to place his earnings beyond her reach.
• Mishandling of cases by Atty. Dela Cruz: Complainant accused Atty. Dela Cruz of mishandling her cases, misrepresenting in open court that she had filed an Answer when she had not, and failing to enforce the PPO against Atty. Ruiz.
• Concealment of whereabouts: Complainant alleged that Atty. Dela Cruz and Atty. Benedicto conspired with Atty. Ruiz to hide his real whereabouts, thereby preventing enforcement of the PPO.

• Harassment suits (Atty. Ruiz): Atty. Ruiz countered that the cases were mere harassment suits filed in retaliation for the adultery case he filed against complainant, and that the standing PPO did not automatically mean he should be disbarred.
• Justifiable refusal to support (Atty. Ruiz): Atty. Ruiz maintained that he refused to provide support because complainant had been adulterous and because Jarren is not his biological child, and that complainant herself failed to cause the execution of the PPO which should have been revoked by operation of law.
• Fabricated MAU (Atty. Ruiz): Atty. Ruiz asserted that the MAU was fabricated since his driver's license used as proof of identity therein was allegedly issued only on April 30, 2013, while the document was executed on January 16, 2012.
• Subsequent compliance (Atty. Ruiz): Atty. Ruiz claimed he eventually gave support to Jarren — paying for school expenses, allowances, and home renovations — which was the reason for the lifting of the PPO, and that he and complainant had already settled their differences.
• Baseless allegations (Atty. Dela Cruz): Atty. Dela Cruz riposted that the allegations against her were baseless, false, and malicious products of complainant's wild imagination, and that she simply followed regular procedure and available remedies under the rules.
• Terminated attorney-client relationship (Atty. Dela Cruz): Atty. Dela Cruz emphasized that her attorney-client relationship with complainant had been terminated after the Anti-VAWC case was resolved in 2008, that she was not engaged as complainant's lawyer in the nullity case, and that she never represented complainant in the estafa case.
• No grounds for liability (Atty. Benedicto): Atty. Benedicto asserted that there were no grounds for administrative liability, as he only represented Atty. Ruiz as a member of the legal profession and did not circumvent any legal processes or commit any misrepresentation in court.

• Conspiracy: Whether all three respondents conspired to commit acts of violence against complainant in violation of the CPR.
• Atty. Ruiz's liability for economic abuse and immoral conduct: Whether Atty. Ruiz violated Rules 1.01, 1.02, and 7.03 of the CPR through his refusal to provide support, execution of the MAU, and maintenance of an illicit relationship.
• Atty. Ruiz's liability for falsehood and misuse of court processes: Whether Atty. Ruiz violated Rules 10.01 and 10.03 of the CPR by using false addresses and abusing his knowledge of the law to circumvent legal processes.
• Atty. Ruiz's liability for delay and impeding execution: Whether Atty. Ruiz violated Rule 12.04 of the CPR by unduly delaying the case and impeding the execution of a judgment.
• Atty. Dela Cruz's liability: Whether Atty. Dela Cruz mishandled complainant's cases and conspired with the other respondents.
• Atty. Benedicto's liability: Whether Atty. Benedicto is administratively liable for representing Atty. Ruiz.
• Proper penalty: Whether disbarment or a lesser penalty is the appropriate sanction for Atty. Ruiz.

• Conspiracy: No. Complainant failed to establish by substantial evidence any conspiracy among the three respondents; the allegation of "synchronized acts of harassment" was unsupported by evidence of the requisite weight and substance.
• Atty. Ruiz's liability for economic abuse and immoral conduct: Yes. Atty. Ruiz violated Rules 1.01, 1.02, and 7.03 of the CPR by decisively depriving complainant and their child of support for at least eight years in defiance of several judicial orders, and by maintaining an illicit relationship recorded in a public document.
• Atty. Ruiz's liability for falsehood and misuse of court processes: Yes. Atty. Ruiz violated Rules 10.01 and 10.03 by systematically using five bogus addresses to evade service of court processes and by exploiting his knowledge of the law to circumvent the PPO and writ of execution.
• Atty. Ruiz's liability for delay and impeding execution: Yes. Atty. Ruiz violated Rule 12.04 by stubbornly refusing to follow court orders for years, aggravated by his repeated change of address to evade execution of the court's issuances.
• Atty. Dela Cruz's liability: No. She merely performed her duty as complainant's counsel, ably represented complainant, and obtained favorable rulings; she did not even represent complainant in the cases where mishandling was alleged.
• Atty. Benedicto's liability: No. He simply acted as counsel for Atty. Ruiz, and absent any showing of punishable acts proven with substantial evidence, he cannot be held administratively liable.
• Proper penalty: Disbarment. The multiple and systematic infractions committed over at least eight years — including abusive use of legal processes, deliberate evasion of court orders, execution of the immoral MAU, and brazen victim-blaming — constitute indelible marks of debauchery and unfitness warranting the supreme penalty.

• Conspiracy: The Court agreed with the Investigating Commissioner that complainant failed to establish conspiracy by substantial evidence. Atty. Dela Cruz merely performed her duty as complainant's counsel and even obtained favorable rulings in complainant's favor in the Anti-VAWC case. Atty. Benedicto simply acted as counsel for Atty. Ruiz. The strategies Atty. Dela Cruz employed were within the bounds of law and the rules. As for the nullity and estafa cases, Atty. Dela Cruz did not even represent complainant, making it impossible for her to have mishandled them or conspired with the other respondents. A lawyer cannot be held responsible for cases she had no hand in, nor for another's liability.

• Atty. Ruiz's liability for economic abuse and immoral conduct: The Court found that Atty. Ruiz committed multiple immoral, deceitful, and dishonest acts. First, he systematically used five bogus addresses throughout the trial court proceedings so court processes could not be legally served on him — a finding he never denied. Second, he executed the MAU with his mistress Radelia on January 16, 2012, which contained provisions placing his properties beyond the reach of execution and expressly excluding Jarren from receiving financial support. The MAU, being a notarized document, enjoyed the presumption of due execution and authenticity, which Atty. Ruiz failed to rebut; his claim that his driver's license was issued post facto was disproven by records showing it was actually issued on April 3, 2011. Third, he refused to provide support for at least eight years despite the final and executory PPO and writ of execution. His defense that Jarren was not his biological child was baseless: Jarren is presumed legitimate under Article 164 of the Family Code, and the declaration of nullity of marriage does not affect the child's legitimate status under Article 54 in relation to Article 36. The Court's prior ruling in Ruiz vs. AAA (G.R. No. 231619) had already established that Atty. Ruiz's obligation to support Jarren does not cease even after the nullity of marriage. The deprivation or denial of financial support to the child constitutes an act of violence against women and children under Section 5(e) of RA 9262. Maintaining an illicit relationship is immoral conduct punishable by either suspension or disbarment; here, the conduct was grossly immoral as Atty. Ruiz left his family, cohabited with another woman, and brazenly recorded their unlawful relationship in a public document.

• Atty. Ruiz's liability for falsehood and misuse of court processes: Atty. Ruiz abused his position as a lawyer and his knowledge of the law to trivialize the authority of the court and undermine the rule of law. He used five different spurious addresses to deceive the court and evade service of court processes, never bothering to explain why he was not found in any of them. In Andaya vs. Atty. Tumanda, the Court considered a lawyer's repeated changing of address to evade obligations as an aggravating circumstance that laid bare the lawyer's lack of integrity. In Sitaca vs. Atty. Palomares, Jr., the Court disbarred a lawyer for indulging in deliberate falsehood. In Genato vs. Atty. Mallari, the Court decreed that lawyers must not only be knowledgeable of the law but must abide by it, and that misuse and abuse of court procedures by lawyers is abhorred. Atty. Ruiz's acts of repeatedly defying court issuances and abusing processes, aggravated by his use of his knowledge of law as a tool to perpetrate disrespect for court dispositions, warranted disbarment.

• Atty. Ruiz's liability for delay and impeding execution: A lawyer who delays the execution of a final and executory judgment subjects himself to disciplinary action for willful violation of his duties to act with good fidelity to the courts. In David vs. Atty. Rongcal, et al., the Court found that filing frivolous motions to delay execution of a final judgment is a blatant disregard of judicial process and a clear violation of the Lawyer's Oath, Canons 1, 10, and 12, and Rules 10.03 and 12.04 of the CPR. Atty. Ruiz stubbornly refused to follow the court's orders for years, aggravated by his repeated change of address to evade execution. His refusal was not a single act but one that dragged on for at least eight years. These acts, standing alone, merit disbarment, all the more when taken together.

• Atty. Dela Cruz's liability: The Court found that Atty. Dela Cruz merely performed her duty as complainant's counsel. She ably represented complainant and obtained favorable rulings in the Anti-VAWC case. The strategies she used were within the bounds of law and the rules. For the nullity and estafa cases, she did not even represent complainant, making it impossible for her to have mishandled them or conspired with the other respondents. Citing Vantage Lightning Philippines, Inc., et al. vs. Atty. Diño Jr., the Court held that disciplinary proceedings are confined to the issue of a lawyer's administrative liability, and matters with no intrinsic link to the lawyer's professional engagement should be threshed out in a proper proceeding. A lawyer cannot be held responsible for cases she had no hand in, nor for another's liability.

• Atty. Benedicto's liability: Atty. Benedicto simply acted as counsel for Atty. Ruiz in the latter's cases. The right to counsel is guaranteed by the Constitution, laws, and the Rules of Court. Absent any showing that he committed punishable acts, proven with substantial evidence, he cannot be held liable for representing his client as deemed proper.

• Proper penalty: The Court rejected the IBP-BOG's reduction of the penalty to one-year suspension. While the IBP-BOG accepted evidence that Atty. Ruiz eventually gave support — the reason for the lifting of the PPO — this subsequent compliance does not negate the multiple infractions already committed over many years. His abusive use of legal processes, deliberate and manipulative evasion of court orders, execution of the immoral and illegal MAU, and brazen arrogance in mocking complainant for her inability to obtain support are indelible marks of debauchery and unfitness. The Court deemed it proper to impose the supreme penalty of disbarment, holding that the noble legal profession is no place for abusers and that the Court does not coddle violators of the VAWC law.

• Good moral character as a continuing requirement for Bar membership — Good moral character is not only a condition precedent for admission to the legal profession but must remain intact to maintain one's good standing. Membership in the Bar is a privilege burdened with conditions, and it can be withdrawn where circumstances concretely show the lawyer's lack of essential qualifications, including good moral character. The Court applied this doctrine by finding Atty. Ruiz's multiple immoral, deceitful, and dishonest acts as demonstrating his unfitness to remain a member of the Bar.

• Burden of proof in disbarment proceedings — The complainant bears the burden to satisfactorily prove the allegations in the complaint. The quantum of proof necessary for a finding of guilt is substantial evidence, i.e., that amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion. Mere allegation is not evidence and is not equivalent to proof; charges based on mere suspicion and speculation cannot be given credence. Applied here to dismiss the complaint against Attys. Dela Cruz and Benedicto, as complainant failed to establish conspiracy by substantial evidence.

• Immutability of final and executory judgments — Final and executory judgments are immutable and unalterable and may no longer be amended by any court even to correct errors of law or fact. The doctrine ensures that all judicial controversies are determined with finality. Applied here to the PPO, which remained valid and effective except as to the grant of legal support in favor of complainant after the nullity of marriage.

• Presumption of due execution and authenticity of notarized documents — A notarized document enjoys the presumption of due execution and authenticity. An unsubstantiated attack on the honesty of the complainant cannot destroy this presumption. Applied here to reject Atty. Ruiz's challenge to the MAU's authenticity; his claim that his driver's license was issued post facto was disproven by records showing it was issued on April 3, 2011, predating the MAU's execution on January 16, 2012.

• Legitimacy of children conceived or born during marriage — Under Article 164 of the Family Code, children conceived or born during the marriage of the parents are legitimate. Under Article 54 in relation to Article 36, the legitimate status of children is not affected by the declaration of nullity of marriage. Applied here to reject Atty. Ruiz's claim that he had no obligation to support Jarren, as Jarren is presumed legitimate and his status was not affected by the decree of nullity.

• Grossly immoral conduct as ground for disbarment — For a lawyer to be disbarred on the ground of immorality, the conduct complained of must be grossly immoral or so corrupt as to constitute a criminal act, or so unprincipled as to be reprehensible to a high degree, or committed under such scandalous or revolting circumstances as to shock the common sense of decency. Applied here to Atty. Ruiz's abandonment of his family, cohabitation with another woman, and execution of the MAU recording their unlawful relationship and agreements in a public document.

• Economic abuse as violence against women and children — The deprivation or denial of financial support to a child is considered an act of violence against women and children under Section 5(e) of RA 9262. Lawyers and judges should be at the forefront in combatting domestic abuse; a lawyer who chooses to be its perpetrator warrants disbarment. Applied here to Atty. Ruiz's eight-year deprivation of court-ordered support.

• "The noble legal profession is simply no place for abusers. The Court does not coddle violators of the VAWC law, nor does it allow them to tarnish its collective dignity." — This passage articulates the Court's rationale for imposing the supreme penalty of disbarment on a lawyer who perpetrates domestic abuse, establishing that the legal profession's collective dignity demands the expulsion of those who violate the VAWC law.

• "Membership in the Bar is a privilege burdened with conditions. As a privilege bestowed by law through the Supreme Court, membership in the Bar can be withdrawn where circumstances concretely show the lawyer's lack of essential qualifications required of them, including good moral character." — This passage states the foundational principle governing disbarment: that Bar membership is a conditional privilege, not a right, and may be withdrawn upon a showing of lack of essential qualifications.

• "Indeed, for all his acts of defiance, arrogance, and patent irresponsibility relative to his duties to his family and his duties as a lawyer, respondent Atty. Ruiz is liable for violating Rules 1.01, 10.2, 7.03 of the CPR for committing economic abuse against Jarren for his refusal to provide support despite court orders and for immoral conduct for maintaining an illicit relationship with his mistress; and 10.01, and 10.03 of the CPR for abusing his unique skills and knowledge as a lawyer to circumvent legal processes and escape liability." — This passage summarizes the Court's comprehensive finding of liability across multiple CPR provisions, linking each violation to the specific acts committed.

• "Verily, the protection of women and children extends to the cleansing of the ranks of lawyers with audacity to evade the duty to support one's family and even violate the directive of the court to do so, especially with deliberate intent and a systematic and unlawful ploy to conceal his properties beyond the reach of legal processes." — This passage, cited from Moya vs. Atty. Oreta, articulates the Court's view that the campaign against domestic violence extends to removing from the Bar those lawyers who systematically evade their duty to support their families.

• Ruiz vs. AAA, G.R. No. 231619, November 15, 2021 — Controlling precedent on the same PPO and support obligation. The Court had previously ruled that the PPO remains valid except as to the grant of legal support in favor of complainant after the nullity of marriage, and that Atty. Ruiz's obligation to provide support to his minor child does not cease even after the nullity. This ruling was extensively relied upon to establish that Atty. Ruiz's support obligation to Jarren persisted despite the dissolution of the marriage.

• Andaya vs. Atty. Tumanda, A.C. No. 12209, February 18, 2020 — Followed. The Court cited this case for the principle that a lawyer's repeated changing of address to evade obligations and failure to participate in proceedings is an aggravating circumstance that lays bare the lawyer's lack of integrity and moral soundness. The Court increased the penalty from one-year suspension to three years in that case; here, it imposed disbarment.

• David vs. Atty. Rongcal, et al., A.C. No. 12103, June 23, 2020 — Followed. The Court cited this case for the principle that filing frivolous motions to delay execution of a final and executory judgment is a blatant disregard of judicial process and a violation of the Lawyer's Oath, Canons 1, 10, and 12, and Rules 10.03 and 12.04 of the CPR.

• Moya vs. Atty. Oreta, A.C. No. 13082, November 16, 2021 — Followed. The Court cited this case for the principle that lawyers should be at the forefront in combatting domestic abuse, and that a lawyer who chooses to be a perpetrator of violence against women and children warrants disbarment.

• Asuncion vs. Atty. Salvado, A.C. No. 13242, July 5, 2022 — Followed. The Court cited this case for the principle that preparing and entering into an illegal Memorandum of Agreement warrants disbarment, especially where it is not an isolated incident.

• Venzon vs. Atty. Peleo III, A.C. No. 9354, August 20, 2019 — Followed. The Court cited this case for the principle that a lawyer who repeatedly fails to give child support and abandons his family to maintain an illicit affair is unbecoming of a member of the legal profession and warrants disbarment.

• Sitaca vs. Atty. Palomares, Jr., A.C. No. 5285, August 14, 2019 — Followed. The Court cited this case for the principle that indulging in deliberate falsehood by presenting falsified documents in court violates Rule 10.01 of the CPR and warrants disbarment.

• Genato vs. Atty. Mallari, A.C. No. 12486, October 15, 2019 — Followed. The Court cited this case for the principle that lawyers must not only be knowledgeable of the law but must abide by it, and that misuse and abuse of court procedures by lawyers is abhorred, warranting disbarment for repeated defiance of court issuances.

• Vantage Lightning Philippines, Inc., et al. vs. Atty. Diño Jr., A.C. No. 7389, July 2, 2019 — Followed. The Court cited this case for the principle that disciplinary proceedings against lawyers are confined to the issue of the lawyer's fitness to practice, and matters with no intrinsic link to the lawyer's professional engagement should be threshed out in a proper proceeding.

• Rule 1.01, Code of Professional Responsibility — "A lawyer shall not engage in unlawful, dishonest, immoral or deceitful conduct." Applied to Atty. Ruiz's execution of the immoral and illegal MAU, his systematic use of false addresses, and his refusal to provide court-ordered support.

• Rule 1.02, Code of Professional Responsibility — "A lawyer shall not counsel or abet activities aimed at defiance of the law or at lessening confidence in the legal system." Applied to Atty. Ruiz's deliberate evasion of court processes and his abuse of legal procedures to circumvent the PPO and writ of execution.

• Rule 7.03, Code of Professional Responsibility — "A lawyer shall not engage in conduct that adversely reflects on his fitness to practice law, nor shall he whether in public or private life, behave in a scandalous manner to the discredit of the legal profession." Applied to Atty. Ruiz's maintenance of an illicit relationship during the subsistence of his marriage and his abandonment of his family.

• Rule 10.01, Code of Professional Responsibility — "A lawyer shall not do any falsehood, nor consent to the doing of any in Court; nor shall he mislead, or allow the Court to be misled by any artifice." Applied to Atty. Ruiz's use of five bogus addresses to mislead the court and evade service of court processes.

• Rule 10.03, Code of Professional Responsibility — "A lawyer shall observe the rules of procedure and shall not misuse them to defeat the ends of justice." Applied to Atty. Ruiz's abuse of his knowledge of the law to circumvent legal processes and his filing of motions to delay execution of the PPO.

• Rule 12.04, Code of Professional Responsibility — "A lawyer shall not unduly delay a case, impede the execution of a judgment or misuse Court processes." Applied to Atty. Ruiz's eight-year refusal to comply with the PPO and writ of execution, and his repeated change of address to evade execution.

• Section 5(e), Republic Act No. 9262 (Anti-VAWC Act) — Defines economic abuse, including the deprivation or denial of financial support to a child, as an act of violence against women and children. Applied to characterize Atty. Ruiz's refusal to provide court-ordered support as economic abuse.

• Section 16, Republic Act No. 9262 — Provides that a permanent protection order shall still be granted even if the charge against the respondent has been dismissed, as long as there is no clear showing that the act from which the order might arise did not exist. Applied to establish that the PPO remained effective regardless of the status of the marriage.

• Section 31, Republic Act No. 9262 — Provides that while a PPO may be appealed, such appeal shall not stay the enforcement of the judgment. Applied to establish that Atty. Ruiz's appeal did not excuse him from complying with the PPO.

• Article 164, Family Code — "Children conceived or born during the marriage of the parents are legitimate." Applied to establish that Jarren is Atty. Ruiz's legitimate child, entitling him to support regardless of Atty. Ruiz's claims about the child's biological parentage.

• Article 54, Family Code — Children conceived or born before the judgment of annulment or absolute nullity of the marriage under Article 36 has become final and executory shall be considered legitimate. Applied to establish that the declaration of nullity of marriage did not affect Jarren's legitimate status.

• Article 36, Family Code — A marriage contracted by any party who, at the time of the celebration, was psychologically incapacitated to comply with the essential marital obligations of marriage, shall be void. Applied in relation to Article 54 to establish that the nullity of marriage did not extinguish Atty. Ruiz's obligation to support Jarren.

Gesmundo, C.J., Leonen, SAJ., Caguioa, Hernando, Lazaro-Javier, Inting, Zalameda, M. Lopez, Gaerlan, Rosario, J. Lopez, Dimaampao, Marquez, Kho, Jr., and Singh, JJ., concur.