In Re: Edillon

Facts: Edillon refused to pay his membership dues to the IBP arguing that it constitutes an invasion
of his constitutional rights in the sense that he is being compelled to be a member of the Bar and
to pay corresponding dues; deprived of the rights to liberty and property guaranteed to him by the
Constitution.
Issue: WON payment of membership dues invades constitutional rights.
Ruling: No. Integration of the Bar is essentially a process by which every member of the Bar is
afforded an opportunity to do his share in carrying out the objectives of the Bar as well as obliged
to bear his portion of its responsibilities. They are, therefore, subject to all the rules prescribed for
the governance of the Bar, including the requirement of payment of a reasonable annual fee for the
effective discharge of the purposes of the Bar, and adherence to a code of professional ethics or
professional responsibility breach of which constitutes sufficient reason for investigation by the
Bar and, upon proper cause appearing, a recommendation for discipline or disbarment of the
offending member.
The Act's avowal is to "raise the standards of the legal profession, improve the administration of
justice, and enable the Bar to discharge its public responsibility more effectivity." Hence, the
Congress in enacting such Act, the Court in ordaining the integration of the Bar through its
Resolution promulgated on January 9, 1973, and the President of the Philippines in decreeing the
constitution of the IBP into a body corporate through Presidential Decree No. 181 dated May 4,
1973, were prompted by fundamental considerations of public welfare and motivated by a desire
to meet the demands of pressing public necessity.
But the most compelling argument sustaining the constitutionality and validity of Bar integration
in the Philippines is the explicit unequivocal grant of precise power to the Supreme Court by
Section 5 (5) of Article X of the 1973 Constitution of the Philippines.
To compel a lawyer to be a member of the IBO is not violative of his constitutional freedom to
associate. The only compulsion to which he is subjected is the payment of annual dues. Assuming
that the questioned provision does in a sense compel a lawyer to be a member of the Integrated
Bar, such compulsion is justified as an exercise of the police power of the state.
DISBARRED.