The extramarital act, to warrant disbarment, need not even show that it was executed under scandalous circumstances. Instead, the fact of engaging in extramarital affairs sufficiently warrants the disciplinary action against the lawyer. In the case of Eala v. Guevarra , Eala admittedly maintained relationship with Mary Anne Moje, who was married to the complainant. Out of that illicit relationship, Moje gave birth to a child, which Eala acknowledged. In the disbarment case filed against Eala, he insisted that disbarment does not lie because his relationship with Irene was not, under Section 27 of Rule 138 of the Revised Rules of Court, grossly immoral under scandalous circumstances.
The Court was not convinced and went to discuss that: