ITL_-_A | Atty.
Ang
RULE 138
Attorneys and Admission to Bar
Section 1. Who may practice law. — Any person heretofore duly
admitted as a member of the bar, or hereafter admitted as such in
accordance with the provisions of this rule, and who is in good and
regular standing, is entitled to practice law.
Section 2. Requirements for all applicants for admission to the bar.
— Every applicant for admission as a member of the bar must be a
citizen of the Philippines, at least twenty-one years of age, of good
moral character, and resident of the Philippines; and must produce
before the Supreme Court satisfactory evidence of good moral
character, and that no charges against him, involving moral
turpitude, have been filed or are pending in any court in the
Philippines.
Section 3. Requirements for lawyers who are citizens of the United
States of America. — Citizens of the United States of America who,
before July 4, 1946, were duly licensed members of the Philippine
Bar, in active practice in the courts of the Philippines and in good
and regular standing as such may, upon satisfactory proof of those
facts before the Supreme Court, be allowed to continue such practice
after taking the following oath of office:
I . . . . . . . . . . . . . . . . . . . . . . . . . . ., having been permitted to continue
in the practice of law in the Philippines, do solemnly swear that I
recognize the supreme authority of the Republic of the Philippines;
I will support its Constitution and obey the laws as well as the legal
orders of the duly constituted authorities therein; I will do no
falsehood, nor consent to the doing of any in court; I will not
wittingly or willingly promote or sue any groundless, false or
unlawful suit, nor give aid nor consent to the same; I will delay no
man for money or malice, and will conduct myself as a lawyer
according to the best of may knowledge and discretion with all good
fidelity as well as to the courts as to my clients; and I impose upon
myself this voluntary obligation without any mental reservation or
purpose of evasion. So help me God.
Section 4. Requirements for applicants from other jurisdictions. —
Applicants for admission who, being Filipino citizens, are enrolled
attorneys in good standing in the Supreme Court of the United States
or in any circuit court of appeals or district court therein, or in the
highest court of any State or Territory of the United States, and who
can show by satisfactory certificates that they have practiced at least
five years in any of said courts, that such practice began before July
4, 1946, and that they have never been suspended or disbarred, may,
in the discretion of the Court, be admitted without examination.
Section 5. Additional requirements for other applicants. — All
applicants for admission other than those referred to in the two
preceding section shall, before being admitted to the examination,
satisfactorily show that they have regularly studied law for four
years, and successfully completed all prescribed courses, in a law
school or university, officially approved and recognized by the
Secretary of Education. The affidavit of the candidate, accompanied
by a certificate from the university or school of law, shall be filed as
evidence of such facts, and further evidence may be required by the
court.
No applicant shall be admitted to the bar examinations unless he has
satisfactorily completed the following courses in a law school or
university duly recognized by the government: civil law,
commercial law, remedial law, criminal law, public and private
international law, political law, labor and social legislation, medical
jurisprudence, taxation and legal ethics.
Section 6. Pre-Law. — No applicant for admission to the bar
examination shall be admitted unless he presents a certificate that he
has satisfied the Secretary of Education that, before he began the
study of law, he had pursued and satisfactorily completed in an
authorized and recognized university or college, requiring for
admission thereto the completion of a four-year high school course,
the course of study prescribed therein for a bachelor's degree in arts
or sciences with any of the following subjects as major or field of
concentration: political science, logic, english, spanish, history and
economics.
Section 7. Time for filing proof of qualifications. — All applicants
for admission shall file with the clerk of the Supreme Court the
evidence required by section 2 of this rule at least fifteen (15) days
before the beginning of the examination. If not embraced within
section 3 and 4 of this rule they shall also file within the same period
the affidavit and certificate required by section 5, and if embraced
within sections 3 and 4 they shall exhibit a license evidencing the
fact of their admission to practice, satisfactory evidence that the
same has not been revoked, and certificates as to their professional
standing. Applicants shall also file at the same time their own
affidavits as to their age, residence, and citizenship.
Section 8. Notice of Applications. — Notice of applications for
admission shall be published by the clerk of the Supreme Court in
newspapers published in Pilipino, English and Spanish, for at least
ten (10) days before the beginning of the examination.
Section 9. Examination; subjects. — Applicants, not otherwise
provided for in sections 3 and 4 of this rule, shall be subjected to
examinations in the following subjects: Civil Law; Labor and Social
Legislation; Mercantile Law; Criminal Law; Political Law
(Constitutional Law, Public Corporations, and Public Officers);
International Law (Private and Public); Taxation; Remedial Law
(Civil Procedure, Criminal Procedure, and Evidence); Legal Ethics
and Practical Exercises (in Pleadings and Conveyancing).
Section 10.Bar examination, by questions and answers, and in
writing. — Persons taking the examination shall not bring papers,
books or notes into the examination rooms. The questions shall be
the same for all examinees and a copy thereof, in English or Spanish,
shall be given to each examinee. Examinees shall answer the
questions personally without help from anyone.
Upon verified application made by an examinee stating that his
penmanship is so poor that it will be difficult to read his answers
without much loss of time., the Supreme Court may allow such
examinee to use a typewriter in answering the questions. Only
noiseless typewriters shall be allowed to be used.
The committee of bar examiner shall take such precautions as are
necessary to prevent the substitution of papers or commission of
other frauds. Examinees shall not place their names on the
examination papers. No oral examination shall be given.
Section 11.Annual examination. — Examinations for admission to
the bar of the Philippines shall take place annually in the City of
Manila. They shall be held in four days to be disignated by the
chairman of the committee on bar examiners. The subjects shall be
distributed as follows: First day: Political and International Law
(morning) and Labor and Social Legislation (afternoon); Second
day: Civil Law (morning) and Taxation (afternoon); Third day:
Mercantile Law (morning) and Criminal Law (afternoon); Fourth
day: Remedial Law (morning) and legal Ethics and Practical
Exercises (afternoon).
Section 12.Committee of examiners. — Examinations shall be
conducted by a committee of bar examiners to be appointed by the
Supreme Court. This committee shall be composed of a Justice of
the Supreme Court, who shall act as chairman, and who shall be
designated by the court to serve for one year, and eight members of
the bar of the Philippines, who shall hold office for a period of one

year. The names of the members of this committee shall be
published in each volume of the official reports.
Section 13.Disciplinary measures. — No candidate shall endeavor
to influence any member of the committee, and during examination
the candidates shall not communicate with each other nor shall they
give or receive any assistance. The candidate who violates this
provisions, or any other provision of this rule, shall be barred from
the examination, and the same to count as a failure against him, and
further disciplinary action, including permanent disqualification,
may be taken in the discretion of the court.
Section 14.Passing average. — In order that a candidate may be
deemed to have passed his examinations successfully, he must have
obtained a general average of 75 per cent in all subjects, without
falling below 50 per cent in any subjects. In determining the average,
the subjects in the examination shall be given the following relative
weights: Civil Law, 15 per cent; Labor and Social Legislation, 10
per cent; Mercantile Law, 15 per cent; Criminal Law; 10 per cent:
Political and International Law, 15 per cent; Taxation, 10 per cent;
Remedial Law, 20 per cent; Legal Ethics and Practical Exercises, 5
per cent.
Section 15.Report of the committee; filing of examination papers.
— Not later than February 15th after the examination, or as soon
thereafter as may be practicable, the committee shall file its report
on the result of such examination. The examination papers and notes
of the committee shall be filed with the clerk and may there be
examined by the parties in interest, after the court has approved the
report.
Section 16. Failing candidates to take review course. — Candidates
who have failed the bar examinations for three times shall be
disqualified from taking another examination unless they show the
satisfaction of the court that they have enrolled in and passed regular
fourth year review classes as well as attended a pre-bar review
course in a recognized law school.
The professors of the individual review subjects attended by the
candidates under this rule shall certify under oath that the candidates
have regularly attended classes and passed the subjects under the
same conditions as ordinary students and the ratings obtained by
them in the particular subject.
Section 17. Admission and oath of successful applicants. — An
applicant who has passed the required examination, or has been
otherwise found to be entitled to admission to the bar, shall take and
subscribe before the Supreme Court the corresponding oath of
office.
Section 18. Certificate. — The supreme Court shall
thereupon admit the applicant as a member of the bar for all the
courts of the Philippines, and shall direct an order to be entered to
that effect upon its records, and that a certificate of such record be
given to him by the clerk of court, which certificate shall be his
authority to practice.
Section 19. Attorney's roll. — The clerk of the Supreme Court shall
kept a roll of all attorneys admitted to practice, which roll shall be
signed by the person admitted when he receives his certificate.
Section 20. Duties of attorneys. — It is the duty of an attorney:
(a) To maintain allegiance to the Republic of the Philippines and
to support the Constitution and obey the laws of the
Philippines.
(b) To observe and maintain the respect due to the courts of justice
and judicial officers;
ITL_-_A | Atty. Ang
(c) To counsel or maintain such actions or proceedings only as
appear to him to be just, and such defenses only as he believes
to be honestly debatable under the law.
(d) To employ, for the purpose of maintaining the causes confided
to him, such means only as are consistent with truth and honor,
and never seek to mislead the judge or any judicial officer by
an artifice or false statement of fact or law;
(e) To maintain inviolate the confidence, and at every peril to
himself, to preserve the secrets of his client, and to accept no
compensation in connection with his client's business except
from him or with his knowledge and approval;
(f) To abstain from all offensive personality and to advance no
fact prejudicial to the honor or reputation of a party or witness,
unless required by the justice of the cause with which he is
charged;
(g) Not to encourage either the commencement or the continuance
of an action or proceeding, or delay any man's cause, from any
corrupt motive or interest;
(h) Never to reject, for any consideration personal to himself, the
cause of the defenseless or oppressed;
(i) In the defense of a person accused of crime, by all fair and
honorable means, regardless of his personal opinion as to the
guilt of the accused, to present every defense that the law
permits, to the end that no person may be deprived of life or
liberty, but by due process of law.
Section 21. Authority of attorney to appear. — an attorney is
presumed to be properly authorized to represent any cause in which
he appears, and no written power of attorney is required to authorize
him to appear in court for his client, but the presiding judge may, on
motion of either party and on reasonable grounds therefor being
shown, require any attorney who assumes the right to appear in a
case to produce or prove the authority under which he appears, and
to disclose, whenever pertinent to any issue, the name of the person
who employed him, and may thereupon make such order as justice
requires. An attorneys wilfully appear in court for a person without
being employed, unless by leave of the court, may be punished for
contempt as an officer of the court who has misbehaved in his
official transactions.
Section 22. Attorney who appears in lower court presumed to
represent client on appeal. — An attorney who appears de parte in a
case before a lower court shall be presumed to continue representing
his client on appeal, unless he files a formal petition withdrawing
his appearance in the appellate court.
Section 23.Authority of attorneys to bind clients. — Attorneys have
authority to bind their clients in any case by any agreement in
relation thereto made in writing, and in taking appeals, and in all
matters of ordinary judicial procedure. But they cannot, without
special authority, compromise their client's litigation, or receive
anything in discharge of a client's claim but the full amount in cash.
Section 24.Compensation of attorneys; agreement as to fees. — An
attorney shall be entitled to have and recover from his client no more
than a reasonable compensation for his services, with a view to the
importance of the subject matter of the controversy, the extent of the
services rendered, and the professional standing of the attorney. No
court shall be bound by the opinion of attorneys as expert witnesses
as to the proper compensation, but may disregard such testimony
and base its conclusion on its own professional knowledge. A
written contract for services shall control the amount to be paid
therefor unless found by the court to be unconscionable or
unreasonable.

Section 25.Unlawful retention of client's funds; contempt. — When
an attorney unjustly retains in his hands money of his client after it
has been demanded, he may be punished for contempt as an officer
of the Court who has misbehaved in his official transactions; but
proceedings under this section shall not be a bar to a criminal
prosecution.
Section 26.Change of attorneys. — An attorney may retire at any
time from any action or special proceeding, by the written consent
of his client filed in court. He may also retire at any time from an
action or special proceeding, without the consent of his client,
should the court, on notice to the client and attorney, and on hearing,
determine that he ought to be allowed to retire. In case of
substitution, the name of the attorney newly employed shall be
entered on the docket of the court in place of the former one, and
written notice of the change shall be given to the advance party.
A client may at any time dismiss his attorney or substitute another
in his place, but if the contract between client and attorney has been
reduced to writing and the dismissal of the attorney was without
justifiable cause, he shall be entitled to recover from the client the
full compensation stipulated in the contract. However, the attorney
may, in the discretion of the court, intervene in the case to protect
his rights. For the payment of his compensation the attorney shall
have a lien upon all judgments for the payment of money, and
executions issued in pursuance of such judgment, rendered in the
case wherein his services had been retained by the client.
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.
Section 28.Suspension of attorney by the Court of Appeals or a
Court of First Instance. — The Court of Appeals or a Court of First
Instance may suspend an attorney from practice for any of the causes
named in the last preceding section, and after such suspension such
attorney shall not practice his profession until further action of the
Supreme Court in the premises.
Section 29.Upon suspension by the Court of Appeals or Court of
First Instance, further proceedings in Supreme Court. — Upon such
suspension, the Court of Appeals or the Court of First Instance shall
forthwith transmit to the Supreme Court a certified copy of the order
of suspension and a full statement of the facts upon which the same
was based. Upon the receipt of such certified copy and statement,
the Supreme Court shall make a full investigation of the facts
involved and make such order revoking or extending the suspension,
or removing the attorney from his office as such, as the facts warrant.
Section 30.Attorney to be heard before removal or suspension. —
No attorney shall be removed or suspended from the practice of his
profession, until he has had full opportunity upon reasonable notice
to answer the charges against him, to produce witnesses in his own
behalf, and to be heard by himself or counsel. But if upon reasonable
notice he fails to appear and answer the accusation, the court may
proceed to determine the matter ex parte.
Section 31.Attorneys for destitute litigants. — A court may assign
an attorney to render professional aid free of charge to any party in
a case, if upon investigation it appears that the party is destitute and
ITL_-_A | Atty. Ang
unable to employ an attorney, and that the services of counsel are
necessary to secure the ends of justice and to protect the rights of the
party. It shall be the duty of the attorney so assigned to render the
required service, unless he is excused therefrom by the court for
sufficient cause shown.
Section 32.Compensation for attorneys de oficio. — Subject to
availability of funds as may be provided by the law the court may,
in its discretion, order an attorney employed as counsel de oficio to
be compensates in such sum as the court may fix in accordance with
section 24 of this rule. Whenever such compensation is allowed, it
shall be not less than thirty pesos (P30) in any case, nor more than
the following amounts: (1) Fifty pesos (P50) in light felonies; (2)
One hundred pesos (P100) in less grave felonies; (3) Two hundred
pesos (P200) in grave felonies other than capital offenses; (4) Five
Hundred pesos (P500) in capital offenses.
Section 33.Standing in court of person authorized to appear for
Government. — Any official or other person appointed or
designated in accordance with law to appear for the Government of
the Philippines shall have all the rights of a duly authorized member
of the bar to appear in any case in which said government has an
interest direct or indirect.
Section 34.By whom litigation conducted. — In the court of a justice
of the peace a party may conduct his litigation in person, with the
aid of an agent or friend appointed by him for the purpose, or with
the aid an attorney. In any other court, a party may conduct his
litigation personally or by aid of an attorney, and his appearance
must be either personal or by a duly authorized member of the bar.
Section 35.Certain attorneys not to practice. — No judge or other
official or employee of the superior courts or of the Office of the
Solicitor General, shall engage in private practice as a member of
the bar or give professional advice to clients.
Section 36.Amicus Curiae. — Experienced and impartial attorneys
may be invited by the Court to appear as amici curiae to help in the
disposition of issues submitted to it.
Section 37.Attorneys' liens. — An attorney shall have a lien upon
the funds, documents and papers of his client which have lawfully
come into his possession and may retain the same until his lawful
fees and disbursements have been paid, and may apply such funds
to the satisfaction thereof. He shall also have a lien to the same
extent upon all judgments for the payment of money, and executions
issued in pursuance of such judgments, which he has secured in a
litigation of his client, from and after the time when he shall have
the caused a statement of his claim of such lien to be entered upon
the records of the court rendering such judgment, or issuing such
execution, and shall have the caused written notice thereof to be
delivered to his client and to the adverse paty; and he shall have the
same right and power over such judgments and executions as his
client would have to enforce his lien and secure the payment of his
just fees and disbursements.
RULE 138-A
Law Student Practice Rule
Section 1. Conditions for student practice. — A law student who has
successfully completed his 3rd year of the regular four-year
prescribed law curriculum and is enrolled in a recognized law
school's clinical legal education program approved by the Supreme
Court, may appear without compensation in any civil, criminal or
administrative case before any trial court, tribunal, board or officer,
to represent indigent clients accepted by the legal clinic of the law
school.
Section 2. Appearance. — The appearance of the law student
authorized by this rule, shall be under the direct supervision and

control of a member of the Integrated Bar of the Philippines duly
accredited by the law school. Any and all pleadings, motions, briefs,
memoranda or other papers to be filed, must be signed by the
supervising attorney for and in behalf of the legal clinic.
Section 3. Privileged communications. — The Rules safeguarding
privileged communications between attorney and client shall apply
to similar communications made to or received by the law student,
acting for the legal clinic.
Section 4. Standards of conduct and supervision. — The law student
shall comply with the standards of professional conduct governing
members of the Bar. Failure of an attorney to provide adequate
supervision of student practice may be a ground for disciplinary
action. (Circular No. 19, dated December 19, 1986).
Ulep v. The Legal Clinic
June 17, 1993
FACTS:
 The petitioner posits that the advertisements champterous,
unethical, demeaning of the law profession, and destructive of
the confidence of the community in the integrity of the
members of the Bar.
 As a member of the legal profession, he is ashamed and
offended by the said advertisements, hence the reliefs sought
in his petition as hereinbefore quoted.
 Respondent admits the fact of publication of said
advertisement, but claims that it is not engaged in the practice
of law but in the rendering of "legal support services" through
paralegals with the use of modern computers and electronic
machines. Also, assuming that the services advertised are legal
services, the act of advertising these services should be
allowed supposedly in the light of the case of John R. Bates
and Van O'Steen vs. State Bar of Arizona.
 Considering the critical implications on the legal profession of
the issues raised herein, we required the—
(1) Integrated Bar of the Philippines (IBP)
(2) Philippine Bar Association (PBA)
(3) Philippine Lawyers' Association (PLA)
(4) U.P. Womens Lawyers' Circle (WILOCI)
(5) Women Lawyers Association of the Philippines (WLAP)
(6) Federacion International de Abogadas (FIDA)
—to submit their respective position papers on the controversy
and, thereafter, their memoranda.
ISSUE:
 whether or not the services offered by respondent, The Legal
Clinic, Inc., as advertised by it constitutes practice of law
RATIO&RULING:
Integrated Bar of the Philippines
 strongly opposes the view espoused by respondent (to
the effect that today it is alright to advertise one's legal
services)
 invoke the administrative supervision of this Honorable
Court to perpetually restrain respondent from
undertaking highly unethical activities in the field of law
practice as aforedescribed
 the name "The Legal Clinic, Inc." gives the impression
that respondent corporation is being operated by lawyers
and that it renders legal services
 advertisements in question are meant to induce the
performance of acts contrary to law, morals, public order
and public policy
 advertising should be directed exclusively at members of
the Bar, with a clear and unmistakable disclaimer that it
is not authorized to practice law or perform legal services
 nobody should be allowed to represent himself as a
"paralegal" for profit, without such term being clearly
ITL_-_A | Atty. Ang
defined by rule or regulation, and without any adequate
and effective means of regulating his activities
Philippine Bar Association
 respondent's acts of holding out itself to the public under
the trade name "The Legal Clinic, Inc.," and soliciting
employment for its enumerated services fall within the
realm of a practice which thus yields itself to the
regulatory powers of the Supreme Court. For respondent
to say that it is merely engaged in paralegal work is to
stretch credulity
 only natural persons can engage in the practice of law,
and such limitation cannot be evaded by a corporation
employing competent lawyers to practice for it
Philippine Lawyers' Association
 the activities of respondent fall squarely and are
embraced in what lawyers and laymen equally term as
"the practice of law."
U.P. Women Lawyers' Circle
 measures should be taken to protect the general public
from falling prey to those who advertise legal services
without being qualified to offer such services
 advertisements give the impression that information
regarding validity of marriages, divorce, annulment of
marriage, immigration, visa extensions, declaration of
absence, adoption and foreign investment, which are in
essence, legal matters, will be given to them if they avail
of its services
 gives the impression that Respondent will or can cure the
legal problems brought to them
 gives the misleading impression that there are lawyers
involved in The Legal Clinic, Inc., as there are doctors in
any medical clinic, when only "paralegals" are involved
in The Legal Clinic, Inc.
Women Lawyer's Association of the Philippines
 No amount of reasoning can justify the use of
advertisements such as are the subject matter of the
petition, for one (cannot) justify an illegal act even by
whatever merit the illegal act may serve. The law has yet
to be amended so that such act could become justifiable.
 the advertisements that seem to project that secret
marriages and divorce are possible in this country for a
fee, when in fact it is not so, are highly reprehensible.
 Practice of law means any activity, in or out of court, which
requires the application of law, legal procedures, knowledge,
training and experience. To engage in the practice of law is
to perform those acts which are characteristic of the
profession.
 Generally, to practice law is to give advice or render any kind
of service that involves legal knowledge or skill.
 The practice of law is not limited to the conduct of cases in
court. It includes legal advice and counsel, and the preparation
of legal instruments and contract by which legal rights are
secured, although such matter may or may not be pending in a
court.
 In the practice of his profession, a licensed attorney at law
generally engages in three principal types of professional
activity: legal advice and instructions to clients to inform them
of their rights and obligations, preparation for clients of
documents requiring knowledge of legal principles not
possessed by ordinary layman, and appearance for clients
before public tribunals which possess power and authority to
determine rights of life, liberty, and property according to law,
in order to assist in proper interpretation and enforcement of
law.
 One who confers with clients, advises them as to their legal
rights and then takes the business to an attorney and asks the
latter to look after the case in court, is also practicing law.
Giving advice for compensation regarding the legal status and

rights of another and the conduct with respect thereto
constitutes a practice of law. One who renders an opinion as to
the proper interpretation of a statute, and receives pay for it, is,
to that extent, practicing law.
 While some of the services being offered by respondent
corporation merely involve mechanical and technical
knowhow, these will not suffice to justify an exception to the
general rule.
 Respondent corporation gives out legal information to laymen
and lawyers. Its contention that such function is non-advisory
and non-diagnostic is more apparent than real. In providing
information, for example, about foreign laws on marriage,
divorce and adoption, it strains the credulity of this Court that
all the respondent corporation will simply do is look for the
law, furnish a copy thereof to the client, and stop there as if it
were merely a bookstore.
 With its attorneys and so-called paralegals, it will necessarily
have to explain to the client the intricacies of the law and
advise him or her on the proper course of action to be taken as
may be provided for by said law. That is what its
advertisements represent and for the which services it will
consequently charge and be paid. That activity falls squarely
within the jurisprudential definition of "practice of law."
 The nature of the services the respondent renders which
thereby brings it within the ambit of the statutory prohibitions
against the advertisements which it has caused to be published
and are now assailed in this proceeding.
 The reported facts sufficiently establish that the main purpose
of respondent is to serve as a one-stop-shop of sorts for various
legal problems wherein a client may avail of legal services
from simple documentation to complex litigation and
corporate undertakings. Most of these services are
undoubtedly beyond the domain of paralegals, but rather, are
exclusive functions of lawyers engaged in the practice of law.
 It should be noted that in our jurisdiction the services being
offered by private respondent which constitute practice of law
cannot be performed by paralegals. Only a person duly
admitted as a member of the bar, or hereafter admitted as such
in accordance with the provisions of the Rules of Court, and
who is in good and regular standing, is entitled to practice law.
 Public policy requires that the practice of law be limited to
those individuals found duly qualified in education and
character. The permissive right conferred on the lawyers is an
individual and limited privilege subject to withdrawal if he
fails to maintain proper standards of moral and professional
conduct. The purpose is to protect the public, the court, the
client and the bar from the incompetence or dishonesty of
those unlicensed to practice law and not subject to the
disciplinary control of the court.
 The practice of law is not a lawful business except for
members of the bar who have complied with all the conditions
required by statute and the rules of court. Only those persons
are allowed to practice law who, by reason of attainments
previously acquired through education and study, have been
recognized by the courts as possessing profound knowledge of
legal science entitling them to advise, counsel with, protect, or
defend the rights claims, or liabilities of their clients, with
respect to the construction, interpretation, operation and effect
of law.
 The justification for excluding from the practice of law those
not admitted to the bar is found, not in the protection of the bar
from competition, but in the protection of the public from
being advised and represented in legal matters by incompetent
and unreliable persons over whom the judicial department can
exercise little control.
Validity of the questioned advertisements
 the Code of Professional Responsibility provides that a lawyer
in making known his legal services shall use only true, honest,
fair, dignified and objective information or statement of facts.
ITL_-_A | Atty. Ang
 He is not supposed to use or permit the use of any false,
fraudulent, misleading, deceptive, undignified, self-laudatory
or unfair statement or claim regarding his qualifications or
legal services.
 Nor shall he pay or give something of value to representatives
of the mass media in anticipation of, or in return for, publicity
to attract legal business.
 The Canons of Professional Ethics had also warned that
lawyers should not resort to indirect advertisements for
professional employment, such as furnishing or inspiring
newspaper comments, or procuring his photograph to be
published in connection with causes in which the lawyer has
been or is engaged or concerning the manner of their conduct,
the magnitude of the interest involved, the importance of the
lawyer's position, and all other like self-laudation.
 The standards of the legal profession condemn the lawyer's
advertisement of his talents.
 The prescription against advertising of legal services or
solicitation of legal business rests on the fundamental postulate
that the that the practice of law is a profession.
 The canon of the profession tells us that the best advertising
possible for a lawyer is a well-merited reputation for
professional capacity and fidelity to trust, which must be
earned as the outcome of character and conduct.
 Good and efficient service to a client as well as to the
community has a way of publicizing itself and catching public
attention. That publicity is a normal by-product of effective
service which is right and proper. A good and reputable lawyer
needs no artificial stimulus to generate it and to magnify his
success.
 Of course, not all types of advertising or solicitation are
prohibited. The canons of the profession enumerate exceptions
to the rule against advertising or solicitation and define the
extent to which they may be undertaken.
 The first of such exceptions is the publication in reputable law
lists, in a manner consistent with the standards of conduct
imposed by the canons.
 The law list must be a reputable law list published primarily
for that purpose; it cannot be a mere supplemental feature of a
paper, magazine, trade journal or periodical which is published
principally for other purposes.
 A lawyer may not properly publish his brief biographical and
informative data in a daily paper, magazine, trade journal or
society program. Nor may a lawyer permit his name to be
published in a law list the conduct, management or contents of
which are calculated or likely to deceive or injure the public or
the bar, or to lower the dignity or standing of the profession.
 The use of an ordinary simple professional card is also
permitted. The card may contain only a statement of his name,
the name of the law firm which he is connected with, address,
telephone number and special branch of law practiced.
 The publication of a simple announcement of the opening of a
law firm or of changes in the partnership, associates, firm
name or office address, being for the convenience of the
profession, is not objectionable.
 Taking into consideration the nature and contents of the
advertisements for which respondent is being taken to task,
which even includes a quotation of the fees charged by said
respondent corporation for services rendered, we find and so
hold that the same definitely do not and conclusively cannot
fall under any of the above-mentioned exceptions.
 With the present situation of our legal and judicial systems, to
allow the publication of advertisements of the kind used by
respondent would only serve to aggravate what is already a
deteriorating public opinion of the legal profession whose
integrity has consistently been under attack lately by media
and the community in general.

Philippine Lawyers’ Association v. Agrava
February 16, 1959
FACTS:
 Respondent Director issued a circular announcing that he had
scheduled for June 27, 1957 an examination for the purpose of
determining who are qualified to practice as patent attorneys
before the Philippines Patent Office, the said examination to
cover patent law and jurisprudence and the rules of practice
before said office.
 According to the circular, members of the Philippine Bar,
engineers and other persons with sufficient scientific and
technical training are qualified to take the said examination.
 It is the contention of the petitioner Philippine Lawyer's
Association that one who has passed the bar examinations and
is licensed by the Supreme Court to practice law in the
Philippines and who is in good standing, is duly qualified to
practice before the Philippines Patent Office, and that
consequently, the act of the respondent is in excess of his
jurisdiction and is in violation of the law.
 Respondent Director maintains that the prosecution of patent
cases "does not involve entirely or purely the practice of law
but includes the application of scientific and technical
knowledge and training, so much so that, as a matter of actual
practice, the prosecution of patent cases may be handled not
only by lawyers, but also engineers and other persons with
sufficient scientific and technical training who pass the
prescribed examinations as given by the Patent Office. "
 The Rules of Court does not prohibit the exam
 The US allows their Patent Office to hold exams
ISSUE:
 whether or not appearance before the patent Office and the
preparation and the prosecution of patent applications, etc.,
constitutes or is included in the practice of law
RATIO & RULING:
 The Supreme Court has the exclusive and constitutional power
with respect to admission to the practice of law in the
Philippines.
 The practice of law is not limited to the conduct of cases or
litigation in court; it is where the work done involves the
determination by the trained legal mind of the legal effect of
facts and conditions.
 Practice of law under modern conditions consists in no small
part of work performed outside of any court and having no
immediate relation to proceedings in court. It embraces
conveyancing, the giving of legal advice on a large variety of
subjects, and the preparation and execution of legal
instruments covering an extensive field of business and trust
relations and other affairs.
 In our opinion, the practice of law includes such appearance
before the Patent Office, the representation of applicants,
oppositors, and other persons, and the prosecution of their
applications for patent, their oppositions thereto, or the
enforcement of their rights in patent cases.
 In the first place, although the transaction of business in the
Patent Office involves the use and application of technical and
scientific knowledge and training, still, all such business has
to be rendered in accordance with the Patent Law, as well as
other laws, including the Rules and Regulations promulgated
by the Patent Office in accordance with law. Not only this, but
practice before the Patent Office involves the interpretation
and application of other laws and legal principles, as well as
the existence of facts to be established in accordance with the
law of evidence and procedure.
 All the work involve the applications of laws, legal principles,
practice and procedure. They call for legal knowledge, training
and experience for which a member of the bar has been
prepared.
ITL_-_A | Atty. Ang
 In support of the proposition that much of the business and
many of the act, orders and decisions of the Patent Director
involve questions of law or a reasonable and correct evaluation
of facts, the very Patent Law, Republic Act No. 165, Section
61, provides that:
. . . . The applicant for a patent or for the
registration of a design, any party to a proceeding
to cancel a patent or to obtain a compulsory
license, and any party to any other proceeding in
the Office may appeal to the Supreme Court from
any final order or decision of the director.
 In other words, the appeal is taken to this Tribunal. If the
transaction of business in the Patent Office and the acts, orders
and decisions of the Patent Director involved exclusively or
mostly technical and scientific knowledge and training, then
logically, the appeal should be taken not to a court or judicial
body, but rather to a board of scientists, engineers or technical
men, which is not the case.
 The Director of Patents, exercising as he does judicial or quasi-
judicial functions, it is reasonable to hold that a member of the
bar, because of his legal knowledge and training, should be
allowed to practice before the Patent Office, without further
examination or other qualification.
 The Director of Patents, if he deems it advisable or necessary,
may require that members of the bar practicing before him
enlist the assistance of technical men and scientist in the
preparation of papers and documents but respondent Director
claims that he is expressly authorized by the law to require
persons desiring to practice or to do business before him to
submit an examination, even if they are already members of
the bar.
 He contends that our Patent Law, Republic Act No. 165, is
patterned after the United States Patent Law; and of the United
States Patent Office in Patent Cases prescribes an examination
similar to that which he scheduled.
 Respondent Director concludes that Section 78 of Republic
Act No. 165 authorizes him to prescribe the rules and
regulations requiring that persons desiring to practice before
him should submit to and pass an examination.
SEC. 78. Rules and regulations. — The Director
subject to the approval of the Secretary of Justice,
shall promulgate the necessary rules and
regulations, not inconsistent with law, for the
conduct of all business in the Patent Office.
 The above provisions of Section 78 certainly and by far, are
different from the provisions of the United States Patent Law
as regards authority to hold examinations to determine the
qualifications of those allowed to practice before the Patent
Office.
 While the U.S. Patent Law authorizes the Commissioner of
Patents to require attorneys to show that they possess the
necessary qualifications and competence to render valuable
service to and advise and assist their clients in patent cases,
which showing may take the form of a test or examination to
be held by the Commissioner, our Patent Law, Section 78, is
silent on this important point.
 Our attention has not been called to any express provision of
our Patent Law, giving such authority to determine the
qualifications of persons allowed to practice before the Patent
Office.
 Were we to allow the Patent Office, in the absence of an
express and clear provision of law giving the necessary
sanction, to require lawyers to submit to and pass on
examination prescribed by it before they are allowed to
practice before said Patent Office, then there would be no

reason why other bureaus may not also require that any lawyer
practicing before them or otherwise transacting business with
them on behalf of clients, shall first pass an examination to
qualify.
Cojuangco v. Palma
February 16, 1959
FACTS:
 Cojuangco was a client of ACCRA Law and Palma was the
lawyer assigned to handle his cases.
 Owing to his growing business concerns, Cojuangco decided
to hire respondent as his personal counsel; consequently,
respondent's relationship with Cojuangco’s family became
intimate.
 On June 22, 1982, without the knowledge of Cojuangco's
family, respondent married Lisa in Hong Kong. It was only the
next day that respondent informed Cojuangco and assured him
that everything is legal.
 Upon investigation, Cojuangco found that respondent courted
Lisa during their tutoring sessions. Immediately, Cojuangco
sent his two sons to Hongkong to convince Lisa to go home to
Manila and discuss the matter with the family. Lisa was
persuaded.
 Cojuangco also came to know that: (a) on the date of the
supposed marriage, respondent requested from his
Cojuangco's office an airplane ticket to and from Australia,
with stop-over in Hong Kong; (b) respondent misrepresented
himself as bachelor before the Hong Kong authorities to
facilitate his marriage with Lisa; and (c) respondent was
married to Elizabeth Hermosisima and has three children,
namely: Eugene Philippe, Elias Anton and Eduardo Lorenzo.
 On August 24, 1982, Cojuangco filed with the Court of First
Instance, Branch XXVII, Pasay City a petition for declaration
of nullity of the marriage between respondent and Lisa. In the
Decision, the CFI declared the marriage null and void ab initio.
 Thereafter, Cojuangco filed with this Court the instant
complaint for disbarment, imputing to respondent the
following acts:
(a) In grave abuse and betrayal of the trust and confidence,
he took undue advantage of his tutoring sessions with
Maria Luisa by secretly courting her.
(b) Respondent courted Maria Luisa with persistence and
determination and even pursued her in her travels abroad
under false pretenses that he was traveling on official
business for Cojuangco.
(c) With his moral ascendancy over Maria Luisa and his
misrepresentation that there was no legal impediment or
prohibition to his contracting a second marriage,
respondent succeeded in inducing and beguiling her into
marrying him.
ISSUE:
 whether or not respondent acted in a manner violating his oath
as a lawyer
RATIO&RULING:
 The practice of law is a privilege accorded only to those who
measure up to certain rigid standards of mental and moral
fitness. For the admission of a candidate to the bar, the Rules
of Court not only prescribe a test of academic preparation but
require satisfactory testimonials of good moral character.
 These standards are neither dispensed with nor lowered after
admission: the lawyer must continue to adhere to them or else
incur the risk of suspension or removal.
 It must be stressed that the law profession does not prescribe a
dichotomy of standards among its members. There is no
distinction as to whether the transgression is committed in the
lawyers professional capacity or in his private life. This is
because a lawyer may not divide his personality so as to be an
attorney at one time and a mere citizen at another. Thus, not
ITL_-_A | Atty. Ang
only his professional activities but even his private life, insofar
as the latter may reflect unfavorably upon the good name and
prestige of the profession and the courts, may at any time be
the subject of inquiry on the part of the proper authorities.
 While, complainant himself admitted that respondent was a
good lawyer, professional competency alone does not make a
lawyer a worthy member of the Bar. Good moral character is
always an indispensable requirement.
 The ringing truth in this case is that respondent married Lisa
while he has a subsisting marriage with Elizabeth
Hermosisima. Undoubtedly, respondent's act constitutes
grossly immoral conduct, a ground for disbarment under
Section 27, Rule 138 of the Revised Rules of Court. He
exhibited a deplorable lack of that degree of morality required
of him as a member of the Bar. In particular, he made a
mockery of marriage which is a sacred institution demanding
respect and dignity. His act of contracting a second marriage
is contrary to honesty, justice, decency and morality.
 This is not the first occasion that we censure immorality. Thus,
we have somehow come up with a common definition of what
constitutes immoral conduct, i.e., that conduct which is willful,
flagrant, or shameless, and which shows a moral indifference
to the opinion of the good and respectable members of the
community.
 Measured against this definition, respondents act is manifestly
immoral. First, he abandoned his lawful wife and three
children. Second, he lured an innocent young woman into
marrying him. And third, he misrepresented himself as a
bachelor so he could contract marriage in a foreign land.
 The circumstances here speak of a clear case of betrayal of
trust and abuse of confidence. It was respondent's closeness to
the complainant's family as well as the latter's complete trust
in him that made possible his intimate relationship with Lisa.
 When his concern was supposed to be complainant's legal
affairs only, he sneaked behind the latter's back and courted
his daughter. Like the proverbial thief in the night, he attacked
when nobody was looking. Moreover, he availed of
complainant's resources by securing a plane ticket from
complainant's office to marry the latter's daughter in Hong
Kong. He did this without complainant's knowledge.
 Afterwards, he even had the temerity to assure complainant
that everything is legal. Clearly, respondent had crossed the
limits of propriety and decency.
 Respondent's culpability is aggravated by the fact that Lisa
was just a 22-year old college student of Assumption Convent
and was under psychological treatment for emotional
immaturity. Naturally, she was an easy prey.
 Anent respondent’s argument that since the validity of his
marriage to Lisa has not yet been determined by the court with
finality, the same poses a prejudicial question to the present
disbarment proceeding. Suffice it to say that a subsequent
judgment of annulment of marriage has no bearing to the
instant disbarment proceeding. As we held in In re: Almacen,
a disbarment case is sui generis for it is neither purely civil nor
purely criminal but is rather an investigation by the court into
the conduct of its officers.
 So long as the quantum of proof --- clear preponderance of
evidence --- in disciplinary proceedings against members of
the bar is met, then liability attaches.
Of all classes and professions, the lawyer is most sacredly bound to
uphold the laws. He is their sworn servant; and for him, of all men
in the world, to repudiate and override the laws, to trample them
underfoot and to ignore the very bonds of society, argues recreancy
to his position and office and sets a pernicious example to the
insubordinate and dangerous elements of the body politic.

In re: Integration of the Bar of the PH
January 9, 1973
FACTS:
 The petition in Adm. Case No. 526 formally prays the Court
to order the integration of the Philippine Bar, after due hearing,
giving recognition as far as possible and practicable to existing
provincial and other local Bar associations.
 In 1962, arguments in favor of as well as in opposition to the
petition were orally expounded before the Court.
 Since then, the Court has closely observed and followed
significant developments relative to the matter of the
integration of the Bar in this jurisdiction.
 In 1970, the Court created the Commission on Bar Integration
for the purpose of ascertaining the advisability of unifying the
Philippine Bar.
 In 1971, Congress passed House Bill No. 3277 entitled "An
Act Providing for the Integration of the Philippine Bar, and
Appropriating Funds Therefor." The measure was signed by
President Ferdinand E. Marcos on September 17, 1971 and
took effect on the same day as Rep. Act 6397.
 In 1972, the Commission on Bar Integration submitted its
Report with the "earnest recommendation" that "this
Honorable Court ordain the integration of the Philippine Bar
as soon as possible through the adoption and promulgation of
an appropriate Court Rule."
ISSUES:
 whether or not the Court has the power to integrate the
Philippine Bar
 whether or not the integration of the Bar is constitutional
RATIO&RULING:
 Integration of the Philippine Bar means the official unification
of the entire lawyer population of the Philippines. This
requires membership and financial support of every attorney
as conditions sine qua non to the practice of law and the
retention of his name in the Roll of Attorneys of the SC.
 The term "Bar" refers to the collectivity of all persons whose
names appear in the Roll of Attorneys. An Integrated Bar (or
Unified Bar) perforce must include all lawyers.
 Complete unification is not possible unless it is decreed by an
entity with power to do so: the State. Bar integration, therefore,
signifies the setting up by Government authority of a national
organization of the legal profession based on the recognition
of the lawyer as an officer of the court.
 Designed to improve the position of the Bar as an
instrumentality of justice and the Rule of Law, integration
fosters cohesion among lawyers, and ensures, through their
own organized action and participation, the promotion of the
objectives of the legal profession, pursuant to the principle of
maximum Bar autonomy with minimum supervision and
regulation by the Supreme Court.
The purposes of an integrated Bar, in general, are:
(1) Assist in the administration of justice;
(2) Foster and maintain on the part of its members high
ideals of integrity, learning, professional competence,
public service and conduct;
(3) Safeguard the professional interests of its members;
(4) Cultivate among its members a spirit of cordiality and
brotherhood;
(5) Provide a forum for the discussion of law, jurisprudence,
law reform, pleading, practice and procedure, and the
relations of the Bar to the Bench and to the public, and
publish information relating thereto;
(6) Encourage and foster legal education;
(7) Promote a continuing program of legal research in
substantive and adjective law, and make reports and
recommendations thereon; and
ITL_-_A | Atty. Ang
(8) Enable the Bar to discharge its public responsibility
effectively.
Integration of the Bar will, among other things, make it possible
for the legal profession to:
(1) Render more effective assistance in maintaining the Rule
of Law;
(2) Protect lawyers and litigants against the abuse of
tyrannical judges and prosecuting officers;
(3) Discharge, fully and properly, its responsibility in the
disciplining and/or removal of incompetent and
unworthy judges and prosecuting officers;
(4) Shield the judiciary, which traditionally cannot defend
itself except within its own forum, from the assaults that
politics and self-interest may level at it, and assist it to
maintain its integrity, impartiality and independence;
(5) Have an effective voice in the selection of judges and
prosecuting officers;
(6) Prevent the unauthorized practice of law, and break up
any monopoly of local practice maintained through
influence or position;
(7) Establish welfare funds for families of disabled and
deceased lawyers;
(8) Provide placement services, and establish legal aid
offices and set up lawyer reference services throughout
the country so that the poor may not lack competent legal
service;
(9) Distribute educational and informational materials that
are difficult to obtain in many of our provinces;
(10) Devise and maintain a program of continuing legal
education for practising attorneys in order to elevate the
standards of the profession throughout the country;
(11) Enforce rigid ethical standards, and promulgate
minimum fees schedules;
(12) Create law centers and establish law libraries for legal
research;
(13) Conduct campaigns to educate the people on their legal
rights and obligations, on the importance of preventive
legal advice, and on the functions and duties of the
Filipino lawyer; and
(14) Generate and maintain pervasive and meaningful
country-wide involvement of the lawyer population in
the solution of the multifarious problems that afflict the
nation.
 The Court may integrate the Philippine Bar in the exercise of
its power, under Article VIII, Sec. 13 of the Constitution, "to
promulgate rules concerning pleading, practice, and procedure
in all courts, and the admission to the practice of law." Indeed,
the power to integrate is an inherent part of the Court's
constitutional authority over the Bar.
 In providing that "the Supreme Court may adopt rules of court
to effect the integration of the Philippine Bar," Republic Act
6397 neither confers a new power nor restricts the Court's
inherent power, but is a mere legislative declaration that the
integration of the Bar will promote public interest.
Freedom of Association
 To compel a lawyer to be a member of an integrated Bar is not
violative of his constitutional freedom to associate (or the
corollary right not to associate).
 Integration does not make a lawyer a member of any group of
which he is not already a member. All that integration actually
does is to provide an official national organization for the well-
defined but unorganized and incohesive group of which every
lawyer is already a member.
 Membership in the Unified Bar imposes only the duty to pay
dues in reasonable amount.

 Assuming that Bar integration does 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.
 The legal profession has long been regarded as a proper subject
of legislative regulation and control. Moreover, the inherent
power of the Supreme Court to regulate the Bar includes the
authority to integrate the Bar.
Regulatory Fee
 A membership fee in the Integrated Bar is an exaction for
regulation, while the purpose of a tax is revenue. If the Court
has inherent power to regulate the Bar, it follows that as an
incident to regulation, it may impose a membership fee for that
purpose. It would not be possible to push through an Integrated
Bar program without means to defray the concomitant
expenses. The doctrine of implied powers necessarily includes
the power to impose such an exaction.
 The only limitation upon the State's power to regulate the Bar
is that the regulation does not impose an unconstitutional
burden. The public interest promoted by the integration of the
Bar far outweighs the inconsequential inconvenience to a
member that might result from his required payment of annual
dues.
Freedom of Speech
 A lawyer is free, as he has always been, to voice his views on
any subject in any manner he wishes, even though such views
be opposed to positions taken by the Unified Bar.
 For the Integrated Bar to use a member's due to promote
measures to which said member is opposed, would not nullify
or adversely affect his freedom of speech.
Fair to All Lawyers
 Bar integration is not unfair to lawyers already practicing
because although the requirement to pay annual dues is a new
regulation, it will give the members of the Bar a new system
which they hitherto have not had and through which, by proper
work, they will receive benefits they have not heretofore
enjoyed, and discharge their public responsibilities in a more
effective manner than they have been able to do in the past.
 Because the requirement to pay dues is a valid exercise of
regulatory power by the Court, because it will apply equally to
all lawyers, young and old, at the time Bar integration takes
effect, and because it is a new regulation in exchange for new
benefits, it is not retroactive, it is not unequal, it is not unfair.
Cayetano v. Monsod
September 3, 1991
FACTS:
 Respondent Christian Monsod
 nominated by President Aquino
 Chairman of the COMELEC
 Petitioner opposed the nomination because allegedly Monsod
does not possess the required qualification of having been
engaged in the practice of law for at least ten years.
 The Commission on Appointments confirmed the nomination
of Monsod as Chairman of the COMELEC.
 On June 18, 1991, he took his oath of office. On the same day,
he assumed office as Chairman of the COMELEC.
 Petitioner as a citizen and taxpayer, filed the instant petition
for certiorari and Prohibition praying that said confirmation
and the consequent appointment of Monsod as Chairman of
the Commission on Elections be declared null and void.
ISSUE:
 whether or not Monsod did engage in the practice of law for at
least ten years
ITL_-_A | Atty. Ang
RATIO&RULING:
 Atty. Christian Monsod
 member of the Philippine Bar
 passed the bar examinations of 1960 with a grade of 86-
55%
 paid his professional license fees as lawyer for more than
ten years
 worked in the law office of his father
 worked as an operations officer for about two years in
Costa Rica and Panama (while he was in the World Bank
Group)
 involved getting acquainted with the laws of
member-countries negotiating loans and
coordinating legal, economic, and project work
 worked with the Meralco Group
 served as chief executive officer of an investment bank
and subsequently of a business conglomerate
 since 1986, rendered services to various companies as a
legal and economic consultant or chief executive officer
 as former Secretary-General (1986) and National
Chairman (1987) of NAMFREL
 involved being knowledgeable in election law
 appeared for NAMFREL in its accreditation
hearings before the COMELEC
 as former Co-Chairman of the Bishops Businessmen's
Conference for Human Development, has worked with
the underprivileged sectors, such as the farmer and urban
poor groups, in initiating, lobbying for and engaging in
affirmative action for the agrarian reform law and lately
the urban land reform bill
 as for his work as a team negotiator, his capacity as a lawyer
play an important role in any debt restructuring program.
 aside from performing the tasks of legislative drafting
and legal advising, they score national development
policies as key factors in maintaining their countries'
sovereignty.
 Interpreted in the light of the various definitions of the term
Practice of law”, Atty. Monsod's past work experiences verily
more than satisfy the constitutional requirement — that he
has been engaged in the practice of law for at least ten years.
 It is well-settled that when the appointee is qualified, as in this
case, and all the other legal requirements are satisfied, the
Commission has no alternative but to attest to the appointment
in accordance with the Civil Service Law.
 The Commission has no authority to revoke an appointment
on the ground that another person is more qualified for a
particular position.
 It also has no authority to direct the appointment of a substitute
of its choice. To do so would be an encroachment on the
discretion vested upon the appointing authority.
 An appointment is essentially within the discretionary power
of whomsoever it is vested, subject to the only condition that
the appointee should possess the qualifications required by
law.
 The appointing process in a regular appointment as in the case
at bar, consists of four (4) stages:
(1) nomination;
(2) confirmation by the Commission on Appointments;
(3) issuance of a commission (in the Philippines, upon submission
by the Commission on Appointments of its certificate of
confirmation, the President issues the permanent appointment;
and
(4) acceptance e.g., oath-taking, posting of bond, etc.
 The power of the Commission on Appointments to give its
consent to the nomination of Monsod as Chairman of the
Commission on Elections is mandated by Sub-Article C,
Article IX of the Constitution.
 The 1986 Constitution framers has a liberal interpretation of
the practice of law.