Sr. v. Atty. Marietta D. Zamoranos

Summary

Pacasum filed administrative complaint against lawyer Zamoranos for immoral conduct based on alleged bigamous marriage. Zamoranos defended by presenting Shari'a divorce decree from previous marriage under Muslim law. Supreme Court denied petition, ruling that valid divorce decree cannot be collaterally attacked in administrative proceedings. Court applied res judicata principles and conclusiveness of judgment doctrine, noting it had previously upheld same divorce in criminal case. Decision affirms protection of final judgments from collateral attacks and recognizes validity of Muslim divorces under Philippine law when properly obtained from competent Shari'a courts.