B.M. No.

1036 / June 10, 2003

Donna Marie S. Aguirre v. Edwin L. Rana

Facts:
Aguirre filed a petition against Rana, who passed the bar exams in 2000, to deny his admission to the bar
for having represented as counsel a vice-mayoralty candidate in Mandaon, Masbate on 19 of May 2001
at the Municipal Board of Election Canvassers (MBEC) even before he can take his oath as a lawyer on
May 22, 2001. The Office of the Bar Confidant found that he indeed appeared as counsel for the political
candidate and actively participated in the proceedings, and thus, recommended his denial for admission
to the Philippine Bar.

Issue:
Whether or not Rana should be denied admission to the Philippine Bar.

Held:
Yes, Rana should be denied admission to the Philippine Bar. His appearance in the proceedings before
the MBEC and filing of the pleadings constituted practice of law. And doing these without the benefit of
a license constituted an unauthorized practice of law. Though he passed the bar and has taken his oath,
he was not yet signed in the Roll of Attorneys which does not make him a full-fledged lawyer when he
made representations as counsel. In manifestation of being morally unfit to be a member of the Bar, the
Court denied his admission thereto.