The Supreme Court (SC) has disbarred lawyer Eloisa D. Bayani after ruling that she misled a Syrian client into believing he could legally obtain a Philippine passport without undergoing naturalization proceedings, an act that later led to his detention by immigration authorities.
In a per curiam ruling on 18 November 2025, the SC en banc found Bayani guilty of gross misconduct for helping facilitate the acquisition of a fake Philippine passport for Moayad Ahmad Rateb Khorshid, the husband of complainant Marianne Mariano-Khorshid.
The high court said Bayani abused the trust and confidence reposed in her as a lawyer by assuring the couple that Moayad could secure a Philippine passport despite not being naturalized as a Filipino citizen.
“The gravity of respondent’s transgression cannot be overstated,” the SC 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.”
The case stemmed from the couple’s dealings with Bayani after they met her through Marianne’s aunt. Bayani’s law firm later arranged the couple’s civil wedding in the Philippines.
According to Marianne, she asked Bayani whether her Syrian husband could acquire a Philippine passport without naturalization, and the lawyer allegedly told them this was legally possible.
Bayani then introduced the couple to Emiliana Sarte, who supposedly facilitated the processing of the passport.
The lawyer later met the couple in Dubai and personally handed over Moayad’s Philippine passport, along with Marianne’s updated passport reflecting her married name.
The couple paid Bayani for her services.
Believing the passport to be authentic, Moayad used it in business transactions in Dubai and even had his United Arab Emirates visa stamped on the document.
However, in November 2014, when the couple traveled to the Philippines for Moayad’s medical treatment, immigration authorities flagged the passport as fake. Moayad was accosted and detained by the Bureau of Immigration.
Marianne later learned from another lawyer that Philippine citizenship and consequently a Philippine passport could not legally be obtained without naturalization proceedings.
The couple eventually filed a disbarment complaint against Bayani.
In her defense, Bayani denied involvement in procuring the fake passport, claiming she merely introduced the couple to Sarte, whom she described as a travel agency worker.
She also said she only delivered the passports in Dubai and that the documents were sealed in an envelope prepared by Sarte.
But the SC said exchanges of Viber messages, Facebook Messenger chats, SMS, and emails showed Bayani played an active role in securing the fake passport and acted 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.
The tribunal also noted that Bayani had previously faced two other disbarment cases in which she had already been suspended.
The SC said the couple relied in good faith on Bayani’s assurances and suffered emotional and financial harm because of the illegal scheme.
