Reynaria Barcenas vs. Atty.

Anorlito Alvero RULING: The court disbarred Lanuevo – has no authority to request the examiners to re-
A.C. No. 8159 April 23, 2010 evaluate grades of examinees w/o prior authority from Supreme Court.
He does not possess any discretion with respect to the matter of admission of
Facts: On May 7, 2004, Barcenas, through her employee Rodolfo San Antonio, entrusted to Atty. Alvero examinees to the bar. He does not a have any business evaluating the answers of the examinees.
the amount of P300,000, which the latter was supposed to give to a certain Amanda Gasta to redeem
the rights of his deceased father as tenant of a ricefield located in Barangay San Benito, Victoria, Consequently, Galang was also disbarred Sec. 2 of Rule 138 of the Revised Rules of
Laguna. The receipt of the money was evidenced by an acknowledgment receipt dated May 7, 2004. In Curt of 1964, candidates for admission to the bar must be of good moral character. Galang has a
the said receipt, Atty. Alvero said that he would deposit the money in court because Amanda Gasta pending criminal cases of Physical Injuries, he committed perjury when he declared under oath that he
refused to accept the same. had no pending criminal case this resulted him to revoked his license.

Later, Barcenas found out that Atty. Alvero was losing a lot of money in cockfights. To check if the ATTY. ROY B. ECRAELA, v. ATTY. IAN RAYMOND A. PANGALANGAN, Respondent.
money they gave Atty. Alvero was still intact, Barcenas pretended to borrow P80,000.00 from the
P300,000.00 and promised to return the amount when needed or as soon as the case was set for Facts:
hearing. However, Atty. Alvero allegedly replied, “Akala nyo ba ay madali kunin ang pera pag nasa This is a case for disbarment against Atty. Pangalangan for his illicit relations, chronic womanizing,
korte na?” Subsequently, Barcenas discovered that Atty. Alvero did not deposit the money in court, but abuse of authority as an educator, and "other unscrupulous activities" which cause "undue
instead converted and used the same for his personal needs. Despite repeated demands to return the embarrassment to the legal profession."
money, Atty. Alvero refused. Hence, Barcenas filed a case with the IBP. Atty. Alvero stressed that there
was no lawyer-client relationship between him and Barcenas. He, however, insisted that the lawyer- Complainant and respondent were best friends and both graduated from the University of the
client relationship between him and San Antonio still subsisted as his service was never severed by the Philippines (UP) College of Law in 1990, where they were part of a peer group or barkada with several
latter. He further emphasized that he had not breached the trust of his client, since he had, in fact, of their classmates. After passing the bar examinations and being admitted as members of the Bar in
manifested his willingness to return the said amount as long as his lawyer-client relationship with San 1991, they were both registered with the IBP Quezon City.
Antonio subsisted.
Respondent was formerly married to Sheila P. Jardiolin (Jardiolin) with whom he has three (3) children.
Issue: hether or not Atty. Alvero breached Rule 1.01 of Canon 1 and Rules 16.01, 16.02 and 16.03 of Complainant avers that while married to Jardiolin, respondent had a series of adulterous and illicit
Canon 16 of the Code of Professional Responsibility relations with married and unmarried women between the years 1990 to 2007. These alleged illicit
relations involved:
Ruling: Yes. Atty. Alvero breached 1.01 of Canon 1 and Rules 16.01, 16.02 and 16.03 of Canon 16 of 1. AAA, who is the spouse of a colleague in the UP College of Law, from 1990 to 1992,
the Code of Professional Responsibility. There is a clear breach of lawyer-client relations. When a which complainant had personal knowledge of such illicit relations;
lawyer receives money from a client for a particular purpose, the lawyer is bound to render an 2. BBB, sometime during the period from 1992 to 1994 or from 1994 to 1996, despite
accounting to the client showing that the money was spent for a particular purpose. And if he does not being already married to Jardiolin;
use the money for the intended purpose, the lawyer must immediately return the money to his client. 3. CCC, despite being married to Jardiolin and while also being romantically involved
These, Atty. Alvero failed to do. Jurisprudence dictates that a lawyer who obtains possession of the with DDD;
funds and properties of his client in the course of his professional employment shall deliver the same to 4. DDD, sometime during the period from 2000 to 2002, despite still being married to
his client (a) when they become due, or (b) upon demand. In the instant case, respondent failed to Jardiolin and while still being romantically involved with CCC;
account for and return the P300,000.00 despite complainant's repeated demands. 5. EEE, who is related to complainant, sometime during the period from May 2004 until
the filing of the Petition, while still being romantically involved with CCC.
IN RE: VICTORIO LANUEVO(former Bar confidant)
RAMON GALANG (1971 Bar Examinee) flunked in 1969, 1966-76, 1962-64 Bar exam Issue: Should Atty. Pangalangan be disbarred?

FACTS: 1. Administrative proceeding against Victorio Lanuevo for disbarment. Ruling:

2. Admitted having brought the five examination notebooks of Ramon E. Galang Atty. Pangalangan was disbarred by the SC for grossly immoral conduct.
back to the respective examiners for re-evalution or re-checking. CANON 1 - A LAWYER SHALL UPHOLD THE CONSTITUTION, OBEY THE LAWS OF THE LAND
3. The five examiners admitted having re-evaluated or re-checked the notebook to AND PROMOTE RESPECT FOR LAW AND LEGAL PROCESSES.
him by the Bar Confidant, stating that he has the authority to do the same and
that the examinee concerned failed only in his particular subject and was on the Rule 1.01 - A lawyer shall not engage in unlawful, dishonest, immoral or deceitful conduct.
borderline of passing.
4. Ramon galang was able to pass the 1971 bar exam because of Lanuevo’s move CANON 7 - A LAWYER SHALL AT ALL TIMES UPHOLD THE INTEGRITY AND DIGNITY OF THE
but the exam results bears that he failed in 5 subjects namely in (Political, Civil, LEGAL PROFESSION AND SUPPORT THE ACTIVITIES OF THE INTEGRATED BAR.
Mercantile, Criminal & Remedial).
5. Galang on the otherhand, denied of having charged of Slight Physical Injuries on Rule 7.03 - A lawyer shall not engage in conduct that adversely reflects on his fitness to practice law,
Eufrosino de Vera, a law student of MLQU. nor shall he, whether in public or private life. behave in a scandalous manner to the discredit of the legal
profession.
The practice of law is a privilege given to those who possess and continue to possess the legal
qualifications for the profession. Good moral character is not only required for admission to the Bar, but
must also be retained in order to maintain one's good standing in this exclusive and honored fraternity.
In the case at bar, complainant alleged that respondent carried on several adulterous and illicit relations
with both married and unmarried women between the years 1990 to 2007, including complainant's own
wife. Through documentary evidences in the form of email messages, as well as the corroborating
testimonies of the witnesses presented, complainant was able to establish respondent's illicit relations
with DOD and CCC by preponderant evidence.
In sum, Atty. Pangalangan displayed deplorable arrogance by making a mockery out of the institution of
marriage, and taking advantage of his legal skills by attacking the Petition through technicalities and
refusing to participate in the proceedings. His actions showed that he lacked the degree of morality
required of him as a member of the bar, thus warranting the penalty of disbarment.
SPOUSES UMAGUING v. ATTY. DE VERA A.C. No. 10451, February 04, 2015
FACTS: Umaguing ran for the position of SK Chairman but lost to her rival. Complainants lodged an
election protest and engaged in the services of Atty. De Vera. According to the complainants, Atty. De
Vera moved at a glacial pace; he rushed the preparation of the documents and attachments for the
election protest. Two (2) of these attachments are the Affidavits of material witnesses, which was
personally prepared by Atty. De Vera. At the time that the aforesaid affidavits were needed to be signed
by the witnesses, they were unavailable. To remedy this, Atty. De Vera look for the nearest kin of the
witnesses and ask them to sign and he had all the documents notarized. He hastily filed the election
protest with full knowledge that the affidavits were falsified. In further breach of his oath, and for lack of
trust and confidence in the integrity and competency of Atty. De Vera, the complainants withdraw him
as their counsel. Complainants sought Atty. De Vera’s disbarment.
ISSUE 1: Whether or not Atty. De Vera should be held administratively liable.
HELD: Yes. The Supreme Court ruled that, fundamental is the rule that in his dealings with his client
and with the courts, every lawyer is expected to be honest, imbued with integrity, and trustworthy. Xxx
The Lawyer’s Oath enjoins every lawyer not only to obey the laws of the land but also to refrain from
doing any falsehood in or out of court or from consenting to the doing of any in court, and to conduct
himself according to the best of his knowledge and discretion with all good fidelity to the courts as well
as to his clients. xxx In this light, Rule 10.01, Canon 10 of the Code of Professional Responsibility
provides that “[a] lawyer shall not do any falsehood, nor consent to the doing of any in Court; nor shall
he mislead, or allow the Court to be misled by any artifice.”
Atty. De Vera is found guilty of violating the Lawyer’s Oath and Rule 10.01, Canon 10 of the Code of
Professional Responsibility by submitting a falsified document before a court. Disciplinary proceedings
against lawyers are designed to ensure that whoever is granted the privilege to practice law in this
country should remain faithful to the Lawyer’s Oath.
ISSUE 2: Whether or not a case of suspension or disbarment may proceed regardless of interest or lack
of interest of the complainant.
HELD: Yes. A case of suspension or disbarment may proceed regardless of interest or lack of interest
of the complainant. What matters is whether, on the basis of the facts borne out by the record, the
charge of deceit and grossly immoral conduct has been proven. This rule is premised on the nature of
disciplinary proceedings. A proceeding for suspension or disbarment is not a civil action where the
complainant is a plaintiff and the respondent lawyer is a defendant. Disciplinary proceedings involve no
private interest and afford no redress for private grievance. They are undertaken and prosecuted solely
for the public welfare. They are undertaken for the purpose of preserving courts of justice from the
official administration of persons unfit to practice in them. xxx The complainant or the person who called
the attention of the court to the attorney’s alleged misconduct is in no sense a party, and has generally
no interest in the outcome except as all good citizens may have in the proper administration of justice.
Pangan vs. Ramos A.M. No. 1053 September 7, 1979
FACTS:
In 1979, a pending administrative case filed by Santa Pangan against Atty. Dionisio Ramos was
delayed because Atty. Ramos allegedly appeared before a court in Manila. When the records of the
said case was checked (one which Atty. Ramos appeared in), it was found that he used the name
―Atty. Pedro D.D. Ramos‖. In his defense, Atty. Ramos said he has the right to use such name
because in his birth certificate, his name listed was Pedro Dionisio Ramos. ―D.D.‖ stands for Dionisio
Dayaw with Dayaw being his mother‘s surname. However, in the roll of attorneys, his name listed was
Dionisio D. Ramos.
ISSUE:
Whether or not what Atty. Ramos did was correct.
HELD:
No. The attorney‘s roll or register is the official record containing the names and signatures of those
who are authorized to practice law. A lawyer is not authorized to use a name other than the one
inscribed in the Roll of Attorneys in his practice of law. The official oath obliges the attorney solemnly to
swear that he will do no falsehood. As an officer in the temple of justice, an attorney has irrefragable
obligations of truthfulness, candor and frankness. In representing himself to the court as ―Pedro D.D.
Ramos‖ instead of ―Dionisio D. Ramos‖, respondent has violated his solemn oath and has resorted to
deception. The Supreme Court hence severely reprimanded Atty. Ramos and warned that a similar
infraction will warrant suspension or disbarment. PRINCIPLE: The attorney's roll or register is the official
record containing the names and signatures of those who are authorized to practice law. A lawyer is not
authorized to use a name other than the one inscribed in the Roll of Attorneys in his practice of law.
PRESIDING JUDGE JOSE L. MADRID v. ATTY. JUAN S. DEALCA, AC. No. 7474, 2014-09-09
Facts:
On February 7, 2007, Atty. Juan S. Dealca entered his appearance in Criminal Case No. 2006-6795,
entitled "People of the Philippines v. Philip William Arsenault" then pending in Branch 51 of the Regional
Trial Court (RTC) in Sorsogon City, presided by complainant Judge
Jose L. Madrid. [1] Atty. Dealca sought to replace Atty. Vicente Judar who had filed a motion to
withdraw as counsel for the accused. But aside from entering his appearance as counsel for the
accused, Atty. Dealca also moved that Criminal Case No. 2006-6795... be re-raffled to another Branch
of the RTC "[c]onsidering the adverse incidents between the incumbent Presiding Judge and the
undersigned," where "he does not appear before the incumbent Presiding Judge, and the latter does
not also hear cases handled by the... undersigned."[2]
Judge Madrid denied Atty. Dealca's motion to re-raffle through an order issued on February 14, 2007
Consequently, Judge Madrid filed a letter complaint[4] in the Office of the Bar Confidant citing Atty.
Dealca's unethical practice of entering his appearance and then moving for the inhibition of the
presiding judge on the pretext of previous adverse... incidents between them.
IBP Commissioner Salvador B. Hababag ultimately submitted his Report and Recommendation[11]
finding Atty. Dealca guilty of violating the Lawyer's Oath and the Code of Professional Responsibility by
filing frivolous administrative and criminal complaints;... and recommending that Atty. Dealca be
suspended from the practice of law for one year because his motion to inhibit Judge Madrid was devoid
of factual or legal basis, and was grounded on purely personal whims.
In Resolution No. XVIII-2008-41,[12] the IBP Board of Governors modified the recommendation and
dismissed the administrative complaint for its lack of merit
Issues:
(1) Did Atty. Dealca file frivolous administrative and criminal complaints against judges and court
personnel in violation of the Lawyer's Oath and the Code of Professional Responsibility?
(2) Was Atty. Dealca guilty of unethical practice in seeking the inhibition of Judge Madrid in Criminal
Case No. 2006-6795?
Ruling:
We see no merit in Atty. Dealca's arguments.
Although the Court always admires members of the Bar who are imbued with a high sense of vigilance
to weed out from the Judiciary the undesirable judges and inefficient or undeserving court personnel,
any acts taken in that direction should be unsullied by any taint of... insincerity or self-interest. The
noble cause of cleansing the ranks of the Judiciary is not advanced otherwise. It is for that reason that
Atty. Dealca's complaint against Judge Madrid has failed our judicious scrutiny, for the Court cannot find
any trace of idealism or... altruism in the motivations for initiating it. Instead, Atty. Dealca exhibited his
proclivity for vindictiveness and penchant for harassment, considering that, as IBP Commissioner
Hababag pointed out,[16] his bringing of charges against judges, court... personnel and even his
colleagues in the Law Profession had all stemmed from decisions or rulings being adverse to his clients
or his side. He well knew, therefore, that he was thereby crossing the line of propriety, because neither
vindictiveness nor harassment could be a... substitute for resorting to the appropriate legal remedies.
He should now be reminded that the aim of every lawsuit should be to render justice to the parties
according to law, not to harass them.[17]
The Lawyer's Oath is a source of obligations and duties for every lawyer, and any violation thereof by
an attorney constitutes a ground for disbarment, suspension, or other disciplinary action.[18] The oath
exhorts upon the members of the Bar not to
"wittingly or willingly promote or sue any groundless, false or unlawful suit." These are not mere facile
words, drift and hollow, but a sacred trust that must be upheld and keep inviolable.
Rule 1.03 A lawyer shall not, for any corrupt motive or interest, encourage any suit or proceeding or
delay any man's cause.
His being an officer of the court should have impelled him to see to it that the orderly administration of
justice must not be unduly impeded. Indeed, as he must resist the whims and caprices of his clients and
temper his clients' propensities to litigate,[20] so must he equally guard himself against his own
impulses of initiating unfounded suits. While it is the Court's duty to investigate and uncover the truth
behind charges against judges and lawyers, it is equally its duty to shield them from unfounded suits
that... are intended to vex and harass them, among other things.[21]
Moreover, Atty. Dealca must be mindful of his mission to assist the courts in the proper administration of
justice. He disregarded his mission because his filing of the unfounded complaints, including this one
against Judge Madrid, increased the workload of the Judiciary.
Although no person should be penalized for the exercise of the right to litigate, the right must
nonetheless be exercised in good faith.[22] Atty. Dealca's bringing of the numerous administrative and
criminal complaints against judges, court personnel... and his fellow lawyers did not evince any good
faith on his part, considering that he made allegations against them therein that he could not
substantially prove, and are rightfully deemed frivolous and unworthy of the Court's precious time and
serious consideration.
II
Atty. Dealca violated Canon 11 and Rule 11.04... of the Code of Professional Responsibility
Atty. Dealca maintains that Judge Madrid should have "in good grace inhibited himself" upon his motion
to inhibit in order to preserve "confidence in the impartiality of the judiciary."[31] However, IBP
Commissioner Hababag has recommended that Atty. Dealca... be sanctioned for filing the motion to
inhibit considering that the motion, being purely based on his personal whims, was bereft of factual and
legal bases.[32]
The recommendation of IBP Commissioner Hababag is warranted.
Lawyers are licensed officers of the courts empowered to appear, prosecute and defend the legal
causes for their clients. As a consequence, peculiar duties, responsibilities and liabilities are devolved
upon them by law. Verily, their membership in the Bar imposes certain... obligations upon them.[33]
In this regard, Canon 11 and Rule 11.04 of the Code of Professional Responsibility pertinently state:
Canon 11 A lawyer shall observe and maintain the respect due to the courts and to the judicial officers
and should insist on similar conduct by others.
xxxx
Rule 11.04 A lawyer shall not attribute to a Judge motives not supported by the record or have no
materiality to the case.
In light of the foregoing canons, all lawyers are bound to uphold the dignity and authority of the courts,
and to promote confidence in the fair administration of justice. It is the respect for the courts that
guarantees the stability of the judicial institution; elsewise, the... institution would be resting on a very
shaky foundation.
Worth stressing, too, is that the right of a party to seek the inhibition or disqualification of a judge who
does not appear to be wholly free, disinterested, impartial and independent in handling the case must
be balanced with the latter's sacred duty to decide cases without... fear of repression. Thus, it was
incumbent upon Atty. Dealca to establish by clear and convincing evidence the ground of bias and
prejudice in order to disqualify Judge Madrid from participating in a particular trial in which Atty. Dealca
was participating as a... counsel.[36] The latter's bare allegations of Judge Madrid's partiality or hostility
did not suffice,[37] because the presumption that Judge Madrid would undertake his noble role to
dispense justice according to law and the evidence... and without fear or favor should only be overcome
by clear and convincing evidence to the contrary.[38] As such, Atty. Dealca clearly contravened his
duties as a lawyer as expressly stated in Canon 11 and Rule 11.04, supra.
 PETITION FOR AUTHORITY TO CONTINUE USE OF THE FIRM NAME “SYCIP, SALAZAR,
FELICIANO, HERNANDEZ & CASTILLO.” July 30, 1979 RULING: The Court holds that the appearance of Attorney Fule did not constitute private
practice, within the meaning and contemplation of the Rules. Practice is more than isolated
Facts: appearance, for it consists in frequent or customary action, a succession of acts of the same kind. The
Petitions were filed by the surviving partners of Atty. Alexander Sycip, who died on May 5, 1975 and by word private practice of law implies that one must have presented himself to be in the active and
the surviving partners of Atty. Herminio Ozaeta, who died on February 14, 1976, praying that they be continued practice of the legal profession and that his professional services are available to the public
allowed to continue using, in the names of their firms, the names of partners who had passed away. for compensation, as a source of his livelihood or in consideration of his said services. It has never been
Petitioners contend that the continued use of the name of a deceased or former partner when refuted that City Attorney Fule had been given permission by his immediate supervisor, the Secretary of
permissible by local custom, is not unethical but care should be taken that no imposition or deception is Justice, to represent the complainant in the case at bar, who is a relative.
practiced through this use. They also contend that no local custom prohibits the continued use of a
deceased partner’s name in a professional firm’s name; there is no custom or usage in the Philippines, CAYETANO v. MONSOD G.R. No. 100113. September 3, 1991
or at least in the Greater Manila Area, which recognizes that the name of a law firm necessarily
identifies the individual members of the firm. FACTS: Christian Monsod was nominated by then President Corazon C. Aquino as chairman of the
Issue: COMELEC. Cayetano questioned the appointment for Monsod allegedly lacked the necessary
WON the surviving partners may be allowed by the court to retain the name of the partners who already qualification of having been engaged in the practice of law for at least 10 years.
passed away in the name of the firm? NO
The 1987 constitution provides in Section 1, Article IX-C: There shall be a Commission on Elections
Held: composed of a Chairman and six Commissioners who shall be natural-born citizens of the Philippines
In the case of Register of Deeds of Manila vs. China Banking Corporation, the SC said: and, at the time of their appointment, at least thirty-five years of age, holders of a college degree, and
The Court believes that, in view of the personal and confidential nature of the relations between must not have been candidates for any elective position in the immediately preceding
attorney and client, and the high standards demanded in the canons of professional ethics, no practice elections.However, a majority thereof, including the Chairman, shall be members of the Philippine Bar
should be allowed which even in a remote degree could give rise to the possibility of deception. Said who have been engaged in the practice of law for at least ten years.
attorneys are accordingly advised to drop the names of the deceased partners from their firm name.
The public relations value of the use of an old firm name can tend to create undue advantages and It was established that after graduating from the College of Law and hurdling the Bar, respondent
disadvantages in the practice of the profession. An able lawyer without connections will have to make a worked in his father’s law office for a short while, then worked as an Operations Officer in the World
name for himself starting from scratch. Another able lawyer, who can join an old firm, can initially ride on Bank Group for about 2 years, which involved getting acquainted with the laws of member-countries,
that old firm’s reputation established by deceased partners. negotiating loans, and coordinating legal, economic and project work of the Bank. Upon returning to the
The court also made the difference from the law firms and business corporations: Philippines, he worked with the Meralco Group, served as Chief Executive Officer of an investment
A partnership for the practice of law is not a legal entity. It is a mere relationship or association for a bank and has subsequently worked either as Chief Executive Officer or Consultant of various
particular purpose. … It is not a partnership formed for the purpose of carrying on trade or business or companies.
of holding property.” Thus, it has been stated that “the use of a nom de plume, assumed or trade name
in law practice is improper. ISSUE: 1. Whether or not Monsod satisfies the requirement of the position of Chairman of the
We find such proof of the existence of a local custom, and of the elements requisite to constitute the COMELEC. 2. Whether or not the Commission on Appointments committed grave abuse of discretion in
same, wanting herein. Merely because something is done as a matter of practice does not mean that confirming Monsod’s appointment.
Courts can rely on the same for purposes of adjudication as a juridical custom.
Petition suffers legal and ethical impediment. HELD: 1. YES. In the case of Philippine Lawyers Association vs. Agrava: The practice of law is not
limited to the conduct of cases or litigation in court…In general, all advice to clients, and all action taken
for them in matters connected with the law incorporation services, assessment and condemnation
PEOPLE V. VILLANUEVA
services, contemplating an appearance before judicial body, the foreclosure of mortgage, enforcement
of a creditor’s claim in bankruptcy and insolvency proceedings, and conducting proceedings in
FACTS: On Sept. 4, 1959, the Chief of Police of Alaminos, Laguna, charged SImplicio Villanueva with
attachment, and in matters of estate and guardianship have been held to constitute law practice.
crime of Malicious Mischiedf, before the Justice of the Peace Court of said Municipality. Said accused
was represented by counsel de oficio, but later on replaced by counsel de parte. The complainant in
Practice of law means any activity, in or out court, which requires the application of law, legal
the same case was representry by City Attorney Ariston Fule of San Pablo City, having entered his
procedure, knowledge, training and experience. “To engage in the practice of law is to perform those
appearance as private-prosecutor, having secuting the permission of the the Secretary of Justice.
acts which are characteristics of the profession. Generally, to practice law is to give notice or render any
kind of service, which device or service requires the use in any degree of legal knowledge or skill. In
Counsel for the accused presented a “Motion in inhibit Fiscal Fule from Acting as Private prosecutor in
general, a practice of law requires a lawyer and client relationship, it is whether in or out of court.
this case, “this time invoking sec. 32, Rule 127, now sec. 35, Rule 138, Revised Rules, which bars
certain attorneys from practicing.
A person is also considered to be in the practice of law when he: “. . . for valuable consideration
engages in the business of advising person, firms, associations or corporations as to their rights under
ISSUE: Whether of not Atty. Fule violate sec. 32 of Rule 127 now Sec. 35, Rule 138, revised Rules of
the law, or appears in a representative capacity as an advocate in proceedings pending or prospective,
Court, which bars certain attorneys from practicing.
before any court, commissioner, referee, board, body, committee, or commission constituted by law or
authorized to settle controversies. Otherwise stated, one who, in a representative capacity, engages in
the business of advising clients as to their rights under the law, or while so engaged performs any act or
acts either in court or outside of court for that purpose, is engaged in the practice of law.”

Atty. Christian Monsod is a member of the Philippine Bar, having passed the bar examinations of 1960
with a grade of 86.55%. He has been a dues paying member of the Integrated Bar of the Philippines
since its inception in 197273. He has also been paying his professional license fees as lawyer for more
than 10 years. Atty. Monsod’s past work experiences as a lawyer-economist, a lawyer-manager, a
lawyer-entrepreneur of industry, a lawyer-negotiator of contracts, and a lawyer-legislator of both the rich
and the poor — verily more than satisfy the constitutional requirement — that he has been engaged in
the practice of law for at least 10 years.

2. NO. The power of the COA to give consent to the nomination of the Comelec Chairman by the
president is mandated by the constitution. The power of appointment is essentially within the discretion
of whom it is so vested subject to the only condition that the appointee should possess the qualification
required by law. From the evidence, there is no occasion for the SC to exercise its corrective power
since there is no such grave abuse of discretion on the part of the CA.