In The Matter of the Integration of the Bar of the Philippines, January 9, 1973

Facts:
In 1970, the Supreme Court created the Commission on Bar Integration (CBI) to ascertain the
advisability of unifying the Philippine Bar. In 1971, the Congress passed HB 3277 (An Act
Providing for the Integration of the Philippine Bar, and Appropriating Funds Therefor). President
Marcos signed it and it became RA 6397.

In 1972, the CBI submitted its Report with the earnest recommendation to ordain the
integration of the Philippine Bar through the adoption and promulgation of an appropriate
Court Rule. The Report, alongside the proceedings in Administrative Case 526 and the views
and sentiments of the Board of Consultants and the Philippine Bench and Bar, prayed for such
integration.

Issue:
Whether or not, the integration of the Bar is constitutional?

Ruling:
Yes. The integration of the Bar is constitutional.

The CBI Report defines the Bar Integration as the official unification of the entire lawyer
population of the Philippines, requiring membership and financial support of every lawyer as
sine qua non to the practice of law and the retention of his name in the Roll of Attorneys. It is
based on the recognition that a lawyer is an officer of the court. It improves the position of the
Bar as an instrument of justice and rule of law. It fosters cohesion among lawyers and ensures
the promotion of the objectives of the legal profession.

The constitutionality of the Bar Integration hinges on the constitutional rights of freedom of
association and freedom of speech. As the practice of law is a privilege vested with public
interest, it can best discharge its public responsibilities through collective action. Collective
action can only be done through an organized body.

To compel a lawyer to be a member of an Integrated Bar does not violate his constitutional
freedom to associate because integration does not make a lawyer a member of any group of
which he is not already a member. Integration only provides an official national organization for
the well-defined but unorganized and incohesive group of which every lawyer is already a
member. Also, an Integrated Bar serves to elevate the educational and ethical standards of the
Bar with the goal of improving

the quality of the State‘s legitimate interest. Even assuming that a lawyer is compelled to join
the Integrated Bar, it is still a justified compulsion as it is an exercise of the police power of the
State in regulating and controlling the legal profession. Also, the inherent power of the
Supreme Court to regulate the Bar includes the authority to integrate it.

This case falls under Canon 7 but this Canon is not explicitly provided for in the case. However,
the relation can be seen. Canon 7 provides that ―a lawyer shall at all times uphold the integrity
and dignity of the legal profession and support the activities of the integrated bar.‖ In using the
word ―shall,‖ this Canon makes it mandatory for all lawyers to:

a. uphold the integrity and dignity of the legal profession, and (2) support the activities of
the Integrated Bar. In being a member of the Integrated Bar, a lawyer has certain
responsibilities, which, if complied with, will uphold the integrity and dignity of the legal
profession. Therefore, it is neither unlawful to have a Bar Integration nor be a member
of an Integrated Bar.