CANON 7 - A LAWYER SHALL AT ALL TIMES UPHOLD THE INTEGRITY AND DIGNITY OF THE LEGAL PROFESSION AND SUPPORT

THE ACTIVITIES OF THE INTEGRATED BAR. Rule 7.01 - A lawyer shall be answerable for knowingly making a false statement or suppressing a material fact in connection with his application for admission to the bar. Rule 7.02 - A lawyer shall not support the application for admission to the bar of any person known by him to be unqualified in respect to character, education, or other relevant attribute. Rule 7.03 - A lawyer shall not engage in conduct that adversely reflects on his fitness to practice law, nor shall he, whether in public or private life, behave in a scandalous manner to the discredit of the legal profession. ROYONG vs OBLENA FACTS Royong, the niece it the common-law wife of Oblena, filed a rape case against the latter. In her complaint, Royong alleged that in 1958 Oblena forced her to have intercourse with her and that she refrained to report the incident because Oblena threatened to kill her family. As a result if the sexual intercourse, Royong gave birth to a child Oblena denied all the allegations and argued that he and Royong had a relationship and Royong consented tohave intercourse with him. The Solicitor General recommended that Oblena be permanently removed from the roll of attorney even though the acts of the Royong before and after the rape incident showed that she is more of a sweetheart than a victim because of the circumstances behind the incident The Solicitor General also charged Oblena of falsifying and deliberately alleging in his application in the bar in1958 that he is a person of good moral character while having an illicit and adulterous relationship with Briccias Angeles who is not only the aunt of Royong but also has a legal husband in the province (Arines) Oblena moved to dismiss the case because the offenses charged are different from those originally charged in the complaint but the court overruled his petition After the hearing, the investigators concluded that: A.) Oblena used his knowledge in law to commit immoral acts without incurring any criminal liability; B.) He committed gross immorality by continuously cohabiting with Angeles, his common-law wife, even after he became a lawyer and C.) Oblena falsified the truth as to his good moral character in his application to take the bar. ISSUE: W/N the illicit relationship with Royong and the open cohabitation with Angeles, a married woman, are sufficient grounds to cause Oblenas disbarment

RULING: YES! Although Oblena is not yet convicted of the crime of rape, seduction or adultery and he is not guilty of any of the grounds for disbarment enumerated in Sec 25, Rule 127 of the Rules of Court, the enumeration is not exclusive and the power of the court to exclude unworthy members of the bar is inherent and is a necessary incident to the proper administration of justice and can be exercised even without any statutory authority, in all cases unless properly prohibited by statutes. American jurisprudence provides that the continued possession of a good moral character is a requisite condition for the rightful continuance in the practice of law. The loss requires suspension or disbarment even though the statues do not explicitly specify that as a ground of disbarment. Oblenas argument that he believed himself to be a person with good moral character when he filed his application to take the bar examination is wrong. Ones own approximation of himself is not a gauge of his moral character. Moral character is not a subjective term but one which corresponds to objective reality. Moral character is what the person really is and not what he other people thinks he is. His pretension to wait for the 18th birthday of Royong before having carnal knowledge with her shows the scheming mind of Oblena and his taking advantage of his knowledge of the law. Also, Royong is the niece of his common-law wife and he enjoyed moral ascendancy over her. Oblena took advantage of Royongs trust on him. Oblenas contention that the Solicitor General exceeded his authority in filing the present complain which is entirely different from the original complaint filed is untenable. There is nothing in the law requiring the Solicitor General to charge in his complaint the same offence charged in the original complaint. What the law provides is that if the Solicitor General finds sufficient grounds to proceed against the respondent, he shall file the corresponding complaint accompanied by the evidence introduced in his investigation

SAMALA vs PALANA FACTS complainant was looking for a company where he could invest his dollar savings. He met Raymond Taino, a trader-employee of FIRI company o Taino introduced him to FIRI Manager Jun Agustin, Chief Trader Diosdado Bernal, and Legal Officer Antonuitti K. Palaa, the respondent herein. o Complainant expressed his concern to the said three officers of FIRI about having been warned of numerous fraudulent businesses in the Philippines. o Respondent assured him that through FIRI he would be directly putting his investment with Eastern Vanguard Forex Limited, a reputable company based in the Virgin Islands which has been in the foreign exchange business for 13 years. The three officers presented to him their company profile and documents purporting to establish their relationship with Eastern Vanguard Forex Limited. Due to the personal representations and assurances of respondent, Agustin, and Bernal, complainant was convinced and he invested his dollar savings with FIRI Just one month from deposit, he withdrew his investment Agustin told complainant to see Yiu. A check was issued but it was dishonored for insufficiency of funds Respondent gave him another check and a cash. The check according to him was signed by the president and, again, was dishonored. Complainant filed an action for estafa and BP22. Complainant alleged that respondents act of representing himself to be the legal officer of FIRI and his assurance that the check he personally delivered to him was signed in his presence by FIRI Officer Paul Desiderio, when no such person appears to exist, is clearly fraudulent and violative of the Canons of Professional Ethics. He was suspended for 3 years by the IBP

RULING Courth agrees with the decision of IBP Rule 7.03 A lawyer shall not engage in conduct that adversely reflects on his fitness to practice law, nor shall he, whether in public or private life, behave in a scandalous manner to the discredit of the legal profession. In this case, respondent assured complainant that by investing his dollar savings with FIRI, his investment was in a stable company, even if, as it was later discovered, the by-laws of FIRI prohibited it from engaging in investment or foreign exchange business and its primary purpose is to act as consultant in providing professional expertise and reliable data analysis related to partnership and so on. *When complainant decided to withdraw his investment from FIRI, the first check given to him in the amount of his total investment bounced. Thereafter, respondent, as legal officer of FIRI, gave complainant P250,000 in cash and a check for P329,045.09. Respondent assured complainant that the second check was a good check and that it was signed by Paul Desiderio, the alleged president of FIRI. However, the said check bounced because it was drawn against insufficient funds, and the drawer of the check, Paul Desiderio, could not be located when sought to be served a warrant of arrest since his identity was unknown and his residential address was found to be non-existent. Hence, it is clear that the representations of respondent as legal officer of FIRI caused material damage to complainant. In so doing, respondent failed to uphold the integrity and dignity of the legal profession and lessened the confidence of the public in the honesty and integrity of the same. WHEREFORE, respondent Atty. Antonuitti K. Palaa is found GUILTY of violating Rule 7.03 of the Code of Professional Responsibility and hereby SUSPENDED from the practice of law for a period of three (3) years effective

GACIAS vs BALAUITAN FACTS Gacias filed an action for disbarment of Balauitan for dishonesty and grave misconduct Atty. Balauitan owned a parcel of land and sold the same to Gacias. Gacias made a downpayment. Subsequent payments were remitted until it he accumulated an amount of P300,000. The buyer asked for the copy of the title upon learning that the land was a subject of mortgage. Due to failure to produce the copy, he decided not to pursue for the purchase and instead asked for the return of money. The mortgage was foreclosed. According to Atty, the demand for the title is premature since the payment was not yet fully paid. Meanwhile, a case for estafa was filed. IBP ruled for the suspension of Balauitan for 2 years.

RULING When the Code or the Rules speaks of conduct or misconduct, the reference is not confined to ones behavior exhibited in connection with the performance of the lawyers professional duties, but also covers any misconduct which, albeit unrelated to the actual practice of his profession, would show him to be unfit for the office and unworthy of the privileges which his license and the law invest him with. To borrow from Orbe v. Adaza.[6] [T]he grounds expressed in Section 27, Rule 138, of the Rules of Court are not limitative and are broad enough to cover any misconduct, including dishonesty, of a lawyer in his professional or private capacity. Like Atty. Adaza in Orbe, respondent Atty. Bulauitan also refused without justifiable reason to comply with his just obligation under a contract he entered into with the complainant.For, instead of going through the motion of delivering the portion of his property to its buyer after his receipt of almost the entire purchase price therefor, the respondent mortgaged the whole property without so much as informing the complainant about it. Respondent had shown, through his dealing with the complainant involving a tiny parcel of land, a want of professional honesty. Such misdeed reflects on the moral stuff which he is made of. His fitness to continue in the advocacy of law and manage the legal affairs of others are thus put in serious doubt too. The private nature of the transaction or the fact that the same was concluded without the respondent taking advantage of his legal profession is really of little moment. For, a lawyer may be suspended or disbarred for any misconduct, even if it pertains to his private activities, as long as it shows him wanting in honesty, probity or good demeanor. WHEREFORE, herein respondent, ATTY. ALEXANDER BULAUITAN, is found guilty of gross misconduct and dishonesty and ordered SUSPENDED from the practice of law for a period of one (1) year

CANON 8 - A LAWYER SHALL CONDUCT HIMSELF WITH COURTESY, FAIRNESS AND CANDOR TOWARD HIS PROFESSIONAL COLLEAGUES, AND SHALL AVOID HARASSING TACTICS AGAINST OPPOSING COUNSEL. Rule 8.01 - A lawyer shall not, in his professional dealings, use language which is abusive, offensive or otherwise improper. Rule 8.02 - A lawyer shall not, directly or indirectly, encroach upon the professional employment of another lawyer; however, it is the right of any lawyer, without fear or favor, to give proper advice and assistance to those seeking relief against unfaithful or neglectful counsel.

NG vs ALAR FACTS A verified complaint was filed by complainant against Atty. Alar before the Integrated Bar of thePhilippines (IBP), Commission on Bar Discipline (CBD), for Disbarment. The cause of action stemed froman unfavorable decision of the NLRC against the case handled by the respondent as counsel where thecounsel resort to undeserved language and disrespectful stance because of the unfavorable decision

RULING
It must be remembered that the language vehicle does not run short of expressions which are emphatic but respectful, convincing but not derogatory, illuminating but not offensive.10 A lawyer's language should be forceful but dignified, emphatic but respectful as befitting an advocate and in keeping with the dignity of the legal profession.11 Submitting pleadings containing countless insults and diatribes against the NLRC and attacking both its moral and intellectual integrity, hardly measures to the sobriety of speech demanded of a lawyer. Respondent's assertion that the NLRC not being a court, its commissioners, not being judges or justices and therefore not part of the judiciary; and that consequently, the Code of Judicial Conduct does not apply to them, is unavailing. In Lubiano v. Gordolla,12 the Court held that respondent became unmindful of the fact that in addressing the NLRC, he nonetheless remained a member of the Bar, an oath-bound servant of the law, whose first duty is not to his client but to the administration of justice and whose conduct ought to be and must be scrupulously observant of law and ethics.13 Respondents argument that labor practitioners are entitled to some latitude of righteous anger is unavailing. It does not deter the Court from exercising its supervisory authority over lawyers who misbehave or fail to live up to that standard expected of them as members of the Bar. Lawyers are duty bound to foster amicable settlement of cases; litigation and adversarial proceedings while a necessary part of the practice is not encouraged, because it will save expenses and help unclogged [sic] the dockets. If the compromise is fair then there is no reason to prevent the same. There is nothing in the countercomplaint which shows that the compromise agreement and waivers executed appear to be unfair, hence no reason to hold lawyers liable for the same. Besides, a "compromise is as often the better part of justice as prudence the part of valor and a lawyer who encourages compromise is no less the clients champion in settlement out of court than he is the clients champion in the battle in court."

DALLONG-GALICIANO vs CASTRO

This administrative case concerns a lawyer who hurled invectives at a Clerk of Court. Members of the bar decorum must at all times comfort themselves in a manner befitting their noble profession. FACTS Atty Rosalie Dallong is the clerk of court of RTC who filed before IBP a case against Atty Castro for unprofessional conduct. That on May 2003, respondent went to the office to inquire whether the complete records of a certain case had already been remanded to the MCTC. (It must be noted that the respondent is not a counsel of record of either parties) Complainant informed respondent that the record had not yet been transmitted since a certified true copy of the decision of the Court of Appeals should first be presented to serve as basis for the transmittal of the records to the court of origin An argument arose between the two. The respondent repeatedly say bad words against complainant Complainant suffered embarrassment infront of her staff Three days after the incident, complainant filed a case before the CBP-IBP. Respondent failed to appear on the date of hearing because according to him his car was rained by bullets. o Respondent also made a public apology o Complainant filed a Manifestation expressing her desire not to appear on the next hearing date in view of respondents public apology, adding that respondent personally and humbly asked for forgiveness which she accepted.

RULING His explanation that he will enter his appearance in the case when its records were already transmitted to the MCTC is unacceptable. Not being the counsel of record and there being no authorization from either the parties to represent them, respondent had no right to impose his will on the clerk of court. Rule 8.02 of the Code of Professional Responsibility states: Rule 8.02A lawyer shall not, directly or indirectly, encroach upon the professional employment of another lawyer; however, it is the right of any lawyer, without fear or favor, to give proper advice and assistance to those seeking relief against unfaithful or neglectful counsel. Through his acts of constantly checking the transmittal of the records of Civil Case No. 784, respondent deliberately encroached upon the legal functions of the counsel of record of that case. It does not matter whether he did so in good faith. Moreover, in the course of his questionable activities relating to Civil Case No. 784, respondent acted rudely towards an officer of the court. He raised his voice at the clerk of court and uttered at her the most vulgar of invectives. Not only was it ill-mannered but also unbecoming considering that he did all these to a woman and in front of her subordinates. Nonetheless, the penalty to be imposed should be tempered owing to the fact that respondent had apologized to the complainant and the latter had accepted it.

This is not to say, however, that respondent should be absolved from his actuations. People are accountable for the consequences of the things they say and do even if they repent afterwards. The fact remains that things done cannot be undone and words uttered cannot be taken back. Hence, he should bear the consequences of his actions. The highest reward that can be bestowed on lawyers is the esteem of their brethren. This esteem cannot be purchased, perfunctorily created, or gained by artifice or contrivance. It is born of sharp contexts and thrives despite conflicting interest. It emanates solely from integrity, character, brains and skills in the honorable performance of professional duty. WHEREFORE, premises considered, respondent is hereby FINED in the amount of TEN THOUSAND (P10,000.00) PESOS with a warning

REYES vs CHIONG FACTS Atty. Ramon Reyes counsel for Zonggi Xu. Atty. Victoriano Chiong, Jr for Chia Hsien Pan. Xu, a Chinese-Taiwanese went into a business venture with Pan. Pan was supposed to set up a Cebu-based fishball, tempura and seafood products factory. He did not establish it, and so Xu asked that his money be returned. Xu then filed a case of estafa against Pan. Prosecutor Salanga then issued a subpoena against Pan. Atty. Chiong then filed a motion to quash, but he also filed a civil complaint for the collection of a sum of moneyand damages as well as for the dissolution of a business venture against Xu, Atty Reyes, and Prosecutor Salanga. He alleged that Salanga was impleaded as an additional defendant because of the irregularities the latter hadcommitted in conducting the criminal investigation he still filed the complaint against Pan in spite of Pansmotions. Atty. Reyes was allegedly impleaded because he allegedly connived with Xu in filing the estafa case which wasbaseless. IBP recommended that Chiong be suspended for 2 years. RULING The lack of involvement of complainant and Prosecutor Salanga in the business transaction subject of the collection suit shows that there was no reason for their inclusion in that case. It appears that respondent took the estafa case as a personal affront and used the civil case as a tool to return the inconvenience suffered by his client. His actions demonstrate a misuse of the legal process. The aim of every lawsuit should be to render justice to the parties according to law, not to harass them. Lawyers should treat their opposing counsels and other lawyers with courtesy, dignity and civility. A great part of their comfort, as well as of their success at the bar, depends upon their relations with their professional brethren. Since they deal constantly with each other, they must treat one another with trust and respect. Any undue ill feeling between clients should not influence counsels in their conduct and demeanor toward each other. Mutual bickering, unjustified recriminations and offensive behavior among lawyers not only detract from the dignity of the legal profession,[19] but also constitute highly unprofessional conduct subject to disciplinary action.

CONTENTION 2: Respondent claims that it was his client who insisted in impleading complainant and Prosecutor Salanga. COURTS ANS: Such excuse is flimsy and unacceptable. While lawyers owe entire devotion to the interests of their clients, their office does not permit violation of the law or any manner of fraud or chicanery. Their rendition of improper service invites stern and just condemnation. Correspondingly, they advance the honor of their profession and the best interests of their clients when they render service or give advice that meets the strictest principles of moral law
The highest reward that can be bestowed on lawyers is the esteem of their professional brethren. This esteem cannot be purchased, perfunctorily created, or gained by artifice or contrivance. It is born of sharp contests and thrives despite conflicting interests. It emanates solely from integrity, character, brains and skill in the honorable performance of professional duty.

CAMBALIZA vs CRISTAL-TENORIO FACTS A disbarment case against Atty Cristal-Tenorio filed by her former employee Ana Cambaliza for deceit, grossly immoral conduct, and malpractice or other gross misconduct in office. DECEIT - that the respondent has been falsely representing herself to be married to Felicisimo R. Tenorio, Jr., who has a prior and subsisting marriage with another woman. GROSSLY IMMORAL CONDUCT - that the respondent caused the dissemination to the public of a libelous affidavit derogatory to Makati City Councilor Divina Alora Jacome. o The respondent would often openly and sarcastically declare to the complainant and her coemployees the alleged immorality of Councilor Jacome. MALPRACTICE OR OTHER GROSS MISCONDUCT IN OFFICE o (1) cooperated in the illegal practice of law by her husband, who is not a member of the Philippine Bar; o (2) converted her clients money to her own use and benefit, which led to the filing of an estafa case against her; and o (3) threatened the complainant and her family on 24 January 2000 with the statement Isang bala ka lang to deter them from divulging respondents illegal activities and transactions. ANSWERS: o Deceit - she declared that she is legally married o grossly immoral conduct - respondent denied that she caused the dissemination of a libelous and defamatory affidavit against Councilor Jacome. On the contrary, it was Councilor Jacome who caused the execution of said document o malpractice or other gross misconduct in office - She claimed that her Cristal-Tenorio Law Office is registered with the Department of Trade and Industry as a single proprietorship, as shown by its Certificate of Registration of Business Name

Further, the respondent averred that this disbarment complaint was filed by the complainant to get even with her. She terminated complainants employment after receiving numerous complaints that the complainant extorted money from different people with the promise of processing their passports and marriages to foreigners, but she reneged on her promise. Likewise, this disbarment complaint is politically motivated: some politicians offered to re-hire the complainant and her cohorts should they initiate this complaint, which they did and for which they were re-hired.

The respondent also flaunted the fact that she had received numerous awards and citations for civic works and exemplary service to the community. She then prayed for the dismissal of the disbarment case for being baseless. RULING The IBP correctly found that the charges of deceit and grossly immoral conduct were not substantiated. In disbarment proceedings, the complainant has the burden of proving his case by convincing evidence.[17] With respect to the estafa case which is the basis for the charge of malpractice or other gross misconduct in office, the respondent is not yet convicted thereof.

We, however, affirm the IBPs finding that the respondent is guilty of assisting in the unauthorized practice of law. A lawyer who allows a non-member of the Bar to misrepresent himself as a lawyer and to practice law is guilty of violating Canon 9 and Rule 9.01 In this case, Felicisimo R. Tenorio, Jr., is not a lawyer, but he holds himself out as one. His wife, the respondent herein, abetted and aided him in the unauthorized practice of the legal profession.

The lawyers duty to prevent, or at the very least not to assist in, the unauthorized practice of law is founded on public interest and policy. 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 lawyer 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. It devolves upon a lawyer to see that this purpose is attained.
WHEREFORE, for culpable violation of Canon 9 and Rule 9.01 of the Code of Professional Responsibility, respondent Atty. Ana Luz B. Cristal-Tenorio is hereby SUSPENDED from the practice of law for a period of six (6) months effective immediately, with a warning that a repetition of the same or similar act in the future will be dealt with more severely.

REPUBLIC vs KENDRICK FACTS This case stemmed from the construction by respondent Kenrick Development Corporation of a concrete perimeter fence around some parcels of land located behind Air Transportation Office (ATO) As a result, the ATO was dispossessed of some 30,228 square meters of prime land. ATO verified the authenticity of respondents titles with the Land Registration Authority o Atty. Jose Loriega, head of the Land Title Verification Task Force of the LRA, submitted his report; that the land allegedly covered by respondents titles was also found to be within Villamor Air Base OSG filed a complaint on revocation, annulment and cancellation of certificates of titles in behalf of the Republic During the pendency of the case, the Senate Blue Ribbon Committee and Committee on Justice and Human Rights conducted a hearing in aid of legislation on the matter of land registration and titling During the congressional hearing held on November 26, 1998, one of those summoned was Atty. Garlitos, respondents former counsel. He testified that he prepared respondents answer and transmitted an unsigned draft to respondents president, Mr. Victor Ong. The signature appearing above his name was not his. He authorized no one to sign in his behalf either. And he did not know who finally signed it. With Atty. Garlitos revelation, the Republic promptly filed an urgent motion to declare Atty Garlitos in default for failure to file an answer. According to the Republic, it was a mere scrap of paper and produced no legal effect. RULING Counsels authority and duty to sign a pleading are personal to him. He may not delegate it to just any person. The signature of counsel constitutes an assurance by him that he has read the pleading; that, to the best of his knowledge, information and belief, there is a good ground to support it; and that it is not interposed for delay. 16Under the Rules of Court, it is counsel alone, by affixing his signature, who can certify to these matters. The preparation and signing of a pleading constitute legal work involving practice of law which is reserved exclusively for the members of the legal profession. Counsel may delegate the signing of a pleading to another lawyer 17 but cannot do so in favor of one who is not. The Code of Professional Responsibility provides: Rule 9.01 A lawyer shall not delegate to any unqualified person the performance of any task which by law may only be performed by a member of the Bar in good standing. Moreover, a signature by agents of a lawyer amounts to signing by unqualified persons, strongly proscribes.
18

something the law

Therefore, the blanket authority respondent claims Atty. Garlitos entrusted to just anyone was void. Any act taken pursuant to that authority was likewise void. There was no way it could have been cured or ratified by Atty. Garlitos subsequent acts.

RULE 138 Attorneys and Admission to Bar 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; (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. RULE 71 Contempt Section 3. Indirect contempt to be punished after charge and hearing. After a charge in writing has been filed, and an opportunity given to the respondent to comment thereon within such period as may be fixed by the court and to be heard by himself or counsel, a person guilty of any of the following acts may be punished for indirect contempt; (a) Misbehavior of an officer of a court in the performance of his official duties or in his official transactions; (b) Disobedience of or resistance to a lawful writ, process, order, or judgment of a court, including the act of a person who, after being dispossessed or ejected from any real property by the judgment or process of any court of competent jurisdiction, enters or attempts or induces another to enter into or upon such real property, for the purpose of executing acts of ownership or possession, or in any manner disturbs the possession given to the person adjudged to be entitled thereto; (c) Any abuse of or any unlawful interference with the processes or proceedings of a court not constituting direct contempt under section 1 of this Rule; (d) Any improper conduct tending, directly or indirectly, to impede, obstruct, or degrade the administration of justice; (e) Assuming to be an attorney or an officer of a court, and acting as such without authority; (f) Failure to obey a subpoena duly served; (g) The rescue, or attempted rescue, of a person or property in the custody of an officer by virtue of an order or process of a court held by him. But nothing in this section shall be so construed as to prevent the court from issuing process to bring the respondent into court, or from holding him in custody pending such proceedings.

RULE 138 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 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