The Supreme Court (SC) has disbarred an attorney who misled a Syrian client into believing he could legally obtain a Philippine passport without undergoing naturalization, a scheme that eventually led to his detention by immigration authorities.

In a per curiam ruling released Tuesday, the High Court found Eloisa D. Bayani guilty of gross misconduct for helping facilitate a fraudulent Philippine passport for Moayad Ahmad Rateb Khorshid, the husband of complainant Marianne Mariano-Khorshid.

The justices ruled that Bayani abused her professional standing by assuring the couple that Moayad could secure the passport despite not holding Philippine citizenship.

“The gravity of respondent’s transgression cannot be overstated,” the Supreme Court said, noting that Bayani used her legal knowledge “to mislead complainants into believing that Moayad could legally obtain a Philippine passport without undergoing naturalization proceedings.”

According to the complaint, the couple retained Bayani after meeting her through a relative. Bayani’s law firm subsequently arranged the couple’s civil wedding in the Philippines.

When Mariano-Khorshid asked if her Syrian husband could acquire a local passport without naturalization, Bayani allegedly stated it was legally possible and introduced them to Emiliana Sarte to facilitate the processing.

Bayani later met the couple in Dubai, where she personally delivered Moayad’s new Philippine passport alongside his wife’s updated passport. The couple paid Bayani for her services and later used the document for business transactions and visa stamping in Dubai, believing it was authentic.

The scheme unraveled in November 2014 when the couple traveled to the Philippines for Moayad’s medical treatment.

Bureau of Immigration (BI) authorities flagged the passport as a forgery, leading to Moayad’s arrest and detention. Mariano-Khorshid later learned from another attorney that Philippine citizenship and passports cannot be legally acquired without formal naturalization.

In her defense, Bayani denied procuring the fake document, claiming she merely introduced the couple to Sarte, whom she described as a travel agency worker. She also contended that she only delivered the documents in Dubai inside a sealed envelope prepared by Sarte.

The SC rejected her defense, stating that logs of Viber messages, Facebook Messenger chats, text messages, and emails proved Bayani played an active role in securing the falsified passport and served as an intermediary in the illegal transaction.

“As a lawyer, respondent is presumed to know that Moayad cannot obtain a Philippine passport unless he is naturalized,” the court said.

 Lade Jean Kabagani