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REPUBLIC OF THE PHILIPPINES

CITY OF MANILA

COMPLAINT-AFFIDAVIT

I, LADY PHILIP INES NA, of legal age, Filipino, with assistance of counsel, do hereby
state under oath that:

1. I am the wife of Atty. Chi Na and the mother of Hong Kong. I am the C.E.O. of Mabuhay
Corporation.

2. I accuse and hereby charge my husband, CHI NA, a member of the Philippine Bar and
a managing partner of Batas Law firm in Manila for violation of his oath as a lawyer and Rule 1.01
of the Code of Professional Responsibility, which provides:

Rule 1.01 – A lawyer shall not engage in unlawful, dishonest, immoral or


deceitful conduct.

Which committed against me when he maliciously entered into two other marriages
while our marriage was still subsisting.

3. On February 14, 2010, I married Chi Na at the Quiapo Church, Manila. We are currently
living in a house owned by my parents. Attached as ANNEX A is a copy of the marriage certificate
of Lady Philip Ines Na and Chi Na.

4. On May 2016, I went to Davao to inspect one of our projects for Mabuhay Corporation,
I met RUS SIA NA, one of our coordinator in Davao office. Both of us were shocked to know that
we have the same husband. Rus Sia Na stated that Chi Na married her in a civil ceremony
celebrated by Judge Ja Pan on March 10, 2015. Attached as ANNEX B is a copy of the marriage
certificate of Rus Sia Na and Chi Na.

5. After I filed a criminal case against Chi Na for bigamy, I also learned that he contracted
another marriage with a girl named Viet Nam, a doctor from Cebu.

6. Viet Nam also filed a case against Chi Na for bigamy after she read in the newspaper
that there was an earlier case filed against him. According to her, she only agreed to marry Chi Na
because she believed in good faith that he was single after he showed her divorce papers obtained
in Galaxy in 2014. Their married was solemnized at the Good Church in Cebu in April 2015.
Attached as ANNEX C is a copy of the marriage certificate of Viet Nam Na and Chi Na.

7. Viet Nam also informed me that she has a 3-year-old son with Chi Na. Attached as
ANNEX D is a copy of the birth certificate of their son.
8. It is clear from the foregoing that Chi Na did not only violated his oath as a lawyer but
his act was contrary to honesty, justice, decency and morality.

9. He also violated Canon 7 of the Code of Professional Responsibility, which provides:

Canon 7 – A lawyer shall at all times uphold the integrity and dignity of the
legal profession as well as Rule 7.03 of the same code, which provides that, a lawyer
shall not engage in conduct that adversely reflects on his fitness to practice law,
nor should he, whether in public or private life, behave in a scandalous manner to
the discredit of the legal profession.

10. Further, Section 27, Rule 138 of the Rules of Court provides:

Section 27. Attorneys removed or suspended by Supreme Court on what


grounds. — A member of the bar may be removed or suspended from his office as
attorney by the Supreme Court for any deceit, malpractice, or other gross
misconduct in such office, grossly immoral conduct, or by reason of his conviction
of a crime involving moral turpitude, or for any violation of the oath which he is
required to take before the admission to practice, or for a wilfull disobedience of
any lawful order of a superior court, or for corruptly or willful appearing as an
attorney for a party to a case without authority so to do. The practice of soliciting
cases at law for the purpose of gain, either personally or through paid agents or
brokers, constitutes malpractice.

12. Clearly, with these acts and omissions of Atty. Chi Na, he should be accordingly
punished and must suffer the maximum penalty sanctioned by law.

I am executing this affidavit to attest to the truth of the foregoing statements and in support
of my prayer for the IMMEDIATE DISBARMENT of ATTY. CHI NA.

Other relief just and equitable under the premise is likewise prayed for.

TO THE TRUTH OF THE FOREGOING, I have signed this Complaint-Affidavit on 19th


Day of September 2019.

LADY PHILIP INES NA


Complainant-Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this 19th day of January 2019.

Notary Public
JELLY BEAN AIRAN S. SANTIAGO

LEGAL WRITING
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