Legal Profession

A.Y. 2020-21, 2nd Semester

Case Title IN THE MATTER OF THE INTEGRATION OF THE BAR OF THE PHILIPPINES
Citation/Date G.R. No. 00 [January 9, 1973]
Relevant Topic Supervision and Control

Facts
1. In 1970, the Supreme Court, convinced by the results of a preliminary survey showing that “there
had grown a strong nationwide sentiment in favor of Bar Integration, created the Commission on
Bar Integration for the for purposes of ascertaining the advisability of unifying the Philippine Bar.

2. In September of 1971, Congress passed H.B. No. 3277 (“An Act Providing for the Integration of
the Philippine Bar, and Appropriating Funds Therefor”). This was signed into law, by then President
Ferdinand E. Marcos, and took effect on September 17, 1971 as R.A. No. 6397.

3. A petition later docketed as Administrative Case No. 526 was filed on July 11, 1972 praying for
the Supreme Court to

4. On December 1, 1972, the Commission on Bar Integration submitted its Report (dated November
30, 1972) with the “earnest recommendation” for the Supreme Court “to ordain the integration of
the Philippine Bar as soon as possible through the adoption and promulgation of an appropriate
Court Rule.”

Issue/s and Ruling

W/N the Court has the power to integrate the Bar
W/N the integration of the Bar would be constitutional
W/N the Court should order the integration of the Bar
Yes, the authority to integrate is an inherent part of the
Court’s authority over the Bar. R.A. No. 6397 didn’t
confer a new power or restrict the Court’s inherent power
when it provided that “the [Court] may adopt rules of
court to effect the integration of the Philippine Bar”; it
was a mere legislative declaration that the integration will
promote public interest.
Yes, said integration would not impinge (i) freedom of
association because “it does not compel a lawyer to
associate with anyone” and assuming that it does, the
compulsion is justified by the exercise of the State’s
police power; (ii) regulatory fee because the doctrine of
implied powers necessarily includes the power to impose
a membership fee for the purposes of regulation and
acquiring the means to defray concomitant expenses; (iii)
freedom of speech because the State can constitutionally
condition the right to practice law upon membership in
the Integrated Bar; and (iv) fair to all lawyers because the
requirement to pay dues will apply equally to all lawyers,
young and old, at the time the integration takes effect.
Yes, on the basis of the benefits of the integration - as
seen in other jurisdictions - and in view of the majority of
the lawyers from all over the archipelago expressing their
unqualified support for the integration of the Bar.

ACCORDINGLY, the Court, by virtue of the power vested in it by Section 13 of Article VII of the Constitution,
hereby ordains the integration of the Bar of the Philippines in accordance with the attached COURT RULE, effective
on January 16, 1973.