GUEVARRA VS. EALA A.C. NO.
7136 AUGUST 1, 2007 HELD:
JOSELANO GUEVARRA VS. ATTY. JOSE EMMANUEL EALA
A.C. NO. 7136|AUGUST 1, 2007
FACTS:
On March 4, 2002 a complaint of disbarment was filed
before the Integrated Bar of the Philippines Committee
on Bar Discipline against Atty. Jose Emmanuel M. Eala
a.k.a. Noli Eala for grossly immoral conduct and
unmitigated violation of the lawyer’s oath. In the
Complaint, Guevarra first met the respondent in January
2000 when his then fiancée Irene Moje introduced
respondent to him as her friend who was married to
Marianne Tantoco with whom he had three children.
After his marriage to Irene on October 7, 2000,
Complainant noticed that from January to March 2001,
Irene had been receiving from respondent Cellphone
calls, as well as messages some which read “I love you,”
“I miss you,” or “Meet you at Megamall.” He also noticed
that Irene habitually went home very late at night or early
in the morning of the following day, and sometimes did
not go home from work. When he asked her
whereabouts, she replied that she slept at her parent’s
house in Binangonan, Rizal or she was busy with her work.
In February or March 2001, complainant saw Irene and
Respondent together on two occasions. On the second
occasion, he confronted them following which Irene
abandoned the conjugal house. On April 22, 2001
complainant went uninvited to Irene’s birthday
celebration at which he saw her and the respondent
celebrating with her family and friends. Out of
embarrassment, anger and humiliation, he left the venue
immediately. Following that incident, Irene went to the
conjugal house and hauled off all her personal
belongings. Complainant later found a handwritten letter
dated October 7, 2007, the day of his wedding to Irene,
Complainant soon saw respondent’s car and that of
Irene constantly parked at No. 71-B11 Street, New Manila
where as he was later learn sometime in April 2001, Irene
was already residing. He also learned still later that when
his friends saw Irene on about January 18, 2002 together
with respondent during a concert, she was pregnant.
ISSUE:
 Whether Concubinage or Adulterous relationship,
be the reason for the disbarment of Atty. Jose
Emmanuel Eala.
Lawyer’s oath stated that a lawyer should support the
Constitution and obey the laws, Meaning he shall not
make use of deceit, malpractice, or other gross
misconduct, grossly immoral conduct, or be convicted in
any crime involving moral turpitude. In the case at bar
Atty. Eala was accused of Concubinage, under ART. 334
of the Revised Penal Code, “ Any husband who shall
keep a mistress in a conjugal dwelling, or, shall have
sexual intercourse, under scandalous circumstances, with
a woman who is not his wife, or shall cohabit with her in
any other place, shall be punished by prision
correccional in its minimum and medium period. Section
2 of ART. XV states that “Marriage, as an inviolable social
institution, is the foundation of the family and shall be
protected by the state. Respondent’s grossly immoral
conduct runs afoul of the constitution and the laws, that
he as a lawyer has sworn to uphold. Hence the court
declared Atty. Jose Emmanul M. Eala DISBARRED for
grossly immoral conduct, violation of his oath of office,
and violation of canon 1, Rule 1.01 and Canon 7, Rule
7.03 of the Code of Professional Responsibility.
PEREZ VS. CATINDIG
A.C. NO. 5816, MARCH 10, 2015
FACTS:
Atty. Tristan A. Catindig admitted to Dr. Elmar Perez that
he was already wed to Lily Corazon Gomez. Atty.
Catindig told Dr. Perez that he was in the process of
obtaining a divorce in a foreign country to dissolve his
marriage to Gomez, and that he would eventually marry
her once the divorce had been decreed. Consequently,
sometime in 1984, Atty. Catindig and Gomez obtained a
divorce decree from the Dominican Republic.
On July 14, 1984, Atty. Catindig married Dr. Perez in the
State of Virginia in the United States of America (USA).
Years later, Dr. Perez came to know that her marriage to
Atty. Catindig is a nullity since the divorce decree that
was obtained from the Dominican Republic by the latter
and Gomez is not recognized by Philippine
laws. Sometime in 1997, Dr. Perez reminded Atty. Catindig
of his promise to legalize their union by filing a petition to
nullify his marriage to Gomez.
Sometime in 2001, Dr. Perez alleged that she received an
anonymous letter in the mail informing her of Atty.
Catindig’s scandalous affair with Atty. Baydo, and that
sometime later, she came upon a love letter written and
signed by Atty. Catindig for Atty. Baydo dated April 25,
2001. In the said letter, Atty. Catindig professed his love to
Atty. Baydo, promising to marry her once his “impediment
is removed.”
On October 31, 2001, Atty. Catindig abandoned Dr.
Perez and their son; he moved to an upscale
condominium in Salcedo Village, Makati City where Atty.
Baydo was frequently seen.
Atty. Catindig, in his Comment, admitted that he married
Gomez on May 18, 1968. He claimed, however, that
immediately after the wedding, Gomez showed signs
that she was incapable of complying with her marital
obligations. Eventually, their irreconcilable differences led
to their de facto separation in 1984.
Atty. Catindig claimed that Dr. Perez knew of the
foregoing, including the fact that the divorce decreed by
the Dominican Republic court does not have any effect
in the Philippines.
Atty. Catindig claimed that his relationship with Dr. Perez
turned sour. Eventually, he left their home in October 2001
to prevent any acrimony from developing.
He denied that Atty. Baydo was the reason that he left
Dr. Perez.
For her part, Atty. Baydo denied that she had an affair
with Atty. Catindig.
IBP – recommended the disbarment of Atty. Catindig for
gross immorality, violation of Rule 1.01, Canon 7 and Rule
7.03 of the Code of Professional Responsibility. Complaint
against Atty. Baydo – dismissed for dearth of evidence.
ISSUE:
 WON the respondents committed gross
immorality, which would warrant their
disbarment.
HELD:
YES. The Code of Professional Responsibility provides:
Rule 1.01 – A lawyer shall not engage in unlawful,
dishonest, immoral or deceitful conduct.
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 7.03 – A lawyer shall not engage in conduct that
adversely reflects on his fitness to practice law, nor should
he, whether in public or private life, behave in a
scandalous manner to the discredit of the legal
profession.
In this regard, Section 27, Rule 138 of the Rules of Court
provides that a lawyer may be removed or suspended
from the practice of law, inter alia, for grossly immoral
conduct.
“A lawyer may be suspended or disbarred for any
misconduct showing any fault or deficiency in his moral
character, honesty, probity or good demeanor.” Immoral
conduct involves acts that are willful, flagrant, or
shameless, and that show a moral indifference to the
opinion of the upright and respectable members of the
community. Immoral conduct is gross when it is so corrupt
as to constitute a criminal act, or so unprincipled as to be
reprehensible to a high degree, or when committed
under such scandalous or revolting circumstances as to
shock the community’s sense of decency. The Court
makes these distinctions, as the supreme penalty of
disbarment arising from conduct requires grossly immoral,
not simply immoral, conduct.
Contracting a marriage during the subsistence of a
previous one amounts to a grossly immoral conduct.
The facts gathered from the evidence adduced by the
parties and, ironically, from Atty. Catindig’s own
admission, indeed establish a pattern of conduct that is
grossly immoral; it is not only corrupt and unprincipled,
but reprehensible to a high degree.
Moreover, assuming arguendo that Atty. Catindig’s claim
is true, it matters not that Dr. Perez knew that their
marriage is a nullity. The fact still remains that he resorted
to various legal strategies in order to render a façade of
validity to his otherwise invalid marriage to Dr. Perez. Such
act is, at the very least, so unprincipled that it is
reprehensible to the highest degree.
Further, after 17 years of cohabiting with Dr. Perez, and
despite the various legal actions he resorted to in order to
give their union a semblance of validity, Atty. Catindig
left her and their son. It was only at that time that he
finally decided to properly seek the nullity of his first
marriage to Gomez. Apparently, he was then already
entranced with the much younger Atty. Baydo, an
associate lawyer employed by his firm.
While the fact that Atty. Catindig decided to separate
from Dr. Perez to pursue Atty. Baydo, in itself, cannot be
considered a grossly immoral conduct, such fact forms
part of the pattern showing his propensity towards
immoral conduct. Lest it be misunderstood, the Court’s
finding of gross immoral conduct is hinged not on Atty.
Catindig’s desertion of Dr. Perez, but on his contracting of
a subsequent marriage during the subsistence of his
previous marriage to Gomez.
Atty. Catindig’s subsequent marriage during the
subsistence of his previous one definitely manifests a
deliberate disregard of the sanctity of marriage and the
marital vows protected by the Constitution and affirmed
by our laws. By his own admission, Atty. Catindig made a
mockery out of the institution of marriage, taking
advantage of his legal skills in the process. He exhibited a
deplorable lack of that degree of morality required of
him as a member of the bar, which thus warrant the
penalty of disbarment.
There is insufficient evidence to prove the affair between
the respondents.
As it is, the evidence that was presented by Dr. Perez to
prove her claim was mere allegation, an anonymous
letter informing her that the respondents were indeed
having an affair and the purported love letter to Atty.
Baydo that was signed by Atty. Catindig.
The Court has consistently held that in suspension or
disbarment proceedings against lawyers, the lawyer
enjoys the presumption of innocence, and the burden of
proof rests upon the complainant to prove the
allegations in his complaint. The evidence required in
suspension or disbarment proceedings is preponderance
of evidence.
ARRIETA VS. LLOSA (A.C. NO. 4369 11/28/1997)
FACTS:
A disbarment case was filed against Atty. Llosa by Pike P.
Arrieta forallegedly notarizing a Deed of Absolute sale,
wherein, vendors noted werealready dead prior to its
execution. In answer, respondent admitted having
notarized the Deed of Absolute Sale. But before affixing
his notarial seal, he first ascertained the authenticity of
the signatures, verified the identities of the signatories,
and determined the voluntariness of its execution.
However, in a later date, the respondent sought to
dismiss the disbarment case admitting to the fact the
instant case is only a product of misunderstanding and
misinterpretation of some facts and is now convinced
that everything is in order. The designated Investigating
Commissioner of the IBP recommended the dismissal of
the instant case. The Board of Governors of the IBP
adopted the above recommendation and resolved to
dismiss the instant case after finding no compelling
reason to continue with the disbarment proceedings.
ISSUE:
 Whether or not Atty. Joel A. Llosa be disbarred or
suspended from practice of law.
HELD:
YES. Respondent ordered SUSPENDED for six months from
practice of law with a warning that another infraction will
be dealt with more severely. Citing Section 1 of Public Act
No. 2103 also known as the Notarial law, the Supreme
Court explained the importance of adherence to said
law as part of the responsibility of a duly deputized
authority to conduct such notarial process.
Due diligence is to be observed, this being part of a
lawyers professional responsibility and procedural lapse is
not an excuse to cater to the convenience of clients. Any
violation is tantamount to misconduct. Such misconduct
is a ground for disbarment as stated by the Section 27 of
Rule 138 of the Rules of Court. Furthermore, the Supreme
Court stressed the primary responsibility of lawyers as
stated in Canon I of the Code of Professional
Responsibility that a lawyer shall uphold the Constitution,
obey the laws of the land and promote respect for law
and legal processes. A lawyer must also refrain from
engaging in unlawful, dishonest, immoral or deceitful
conduct. Any violation of his oath or of his duties as an
attorney and counsellor, which include statutory grounds
enumerated in Section 27, Rule 138 of the Rules of Court,
all of these being broad enough to cover practically any
misconduct of a lawyer in his professional or private
capacity may be disbarred or suspended.
REYES VS NIEVA | AM NO. 8560
FACTS:
Complainant alleged that she has been working at the
Civil Aviation Authority of the Philippines (CAAP) as an
Administrative Aide on a Job Order basis since October
2004. Sometime in January 2009, she was reassigned at
the CAAP Office of the Board Secretary under the
supervision of respondent, who was then acting as CAAP
Acting Board Secretary. During complainant’s stint under
respondent, she would notice that during office hours,
respondent would often watch “pampagana” videos
saved in his office laptop, all of which turned out to be
pornographic films. Complainant also averred that
whenever respondent got close to her, he would hold her
hand and would sometimes give it a kiss. During these
instances, complainant would remove her hands and tell
him to desist. According to complainant, respondent
even offered her a cellular phone together with the
necessary load to serve as means for their private
communication, but she refused the said offer, insisting
that she already has her own cellular phone and does
not need another one.
Complainant also narrated that at about 5 o’clock in the
afternoon of April 1, 2009, respondent texted her to wait
for him at the office. Fearing that respondent might take
advantage of her, complainant convinced two (2) of her
officemates to accompany her until respondent arrived.
Upon respondent’s arrival and seeing that complainant
had companions, he just told complainant and the other
two (2) office staff to lock the door when they leave.
Complainant further recounted that on the following day,
April 2, 2009, respondent called her on her cellular phone,
asked if she received his text message, and told her he
would tell her something upon his arrival at the office.
At about 9:30 in the morning of even date, respondent
asked complainant to encode a memorandum he was
about to dictate. Suddenly, respondent placed his hand
on complainant’s waist area near her breast and started
caressing the latter’s torso. Complainant immediately
moved away from respondent and told him “sumosobra
na ho kayo sir.” Instead of asking for an apology,
respondent told complainant he was willing to give her
P2,000.00 a month from his own pocket and even gave
her a note stating ‘‘just bet (between) you and me, x x x
kahit na si mommy,” referring to complainant’s mother
who was also working at CAAP. At around past 11
o’clock in the morning of the same day, while
complainant and respondent were left alone in the
office, respondent suddenly closed the door, grabbed
complainant’s arm, and uttered “let’s seal it with a kiss,”
then attempted to kiss complainant. This prompted
complainant to thwart respondent’s advances with her
left arm, raised her voice in order to invite help, and
exclaimed “wag naman kayo ganyan sir, yung asawa
nyo magagalit, sir may asawa ako.” After respondent let
her go, complainant immediately left the office to ask
assistance from her former supervisor who advised her to
file an administrative case against respondent before the
CAAP Committee on Decorum and Investigation (CODI).
Finally, complainant alleged that after her ordeal with
respondent, she was traumatized and was even
diagnosed by a psychiatrist to be suffering from post-
traumatic stress disorder with recurrent major depression.
Eventually, complainant filed the instant complaint.
In his defense respondent denied all of complainant’s
allegations. He maintained that as a 79-year old retiree
who only took a position at the CAAP on a consultancy
basis, it was very unlikely for him to do the acts imputed
against him, especially in a very small office space
allotted for him and his staff. In this regard, he referred to
his Counter-Affidavit8 submitted before the CODI,
wherein he explained, inter alia, that: (a) while he indeed
watches “interesting shows” in his office laptop, he never
invited anyone, including complainant, to watch with him
and that he would even close his laptop whenever
someone comes near him; (b) he never held and kissed
complainant’s hand because if he had done so, he
would have been easily noticed by complainant’s co-
staffers;10 (c) he did offer her a cellular phone, but this
was supposed to be an office phone which should not be
used for personal purposes, and thus, could not be given
any sexual meaning; (d) he did tell complainant to wait
for him in the afternoon of April 1, 2009, but only for the
purpose of having an available encoder should he need
one for any urgent matter that would arise; and (e) he
would not do the acts he allegedly committed on April 2,
2009 as there were other people in the office and that
those people can attest in his favor. Respondent then
pointed out that the administrative case filed against him
before the CODI was already dismissed for lack of basis
and that complainant was only being used by other
CAAP employees who were agitated by the reforms he
helped implement upon his assumption as CAAP
consultant and eventually as Acting Corporate Board
Secretary.
HELD:
Good moral character is a trait that every practicing
lawyer is required to possess. It may be defined as “what
a person really is, as distinguished from good reputation,
or from the opinion generally entertained of him, or the
estimate in which he is held by the public in the place
where he is known. Moral character is not a subjective
term but one which corresponds to objective reality.”
Such requirement has four (4) ostensible purposes,
namely: (a) to protect the public; (b) to protect the
public image of lawyers; (c) to protect prospective
clients; and (d) to protect errant lawyers from themselves.
Verily, lawyers are expected to abide by the tenets of
morality, not only upon admission to the Bar but also
throughout their legal career, in order to maintain their
good standing in this exclusive and honored fraternity.
They may be suspended from the practice of law or
disbarred for any misconduct, even if it pertains to his
private activities, as long as it shows him to be wanting in
moral character, honesty, probity or good demeanor.
Without a doubt, it has been established that respondent
habitually watches pornographic materials in his office-
issued laptop while inside the office premises, during
office hours, and with the knowledge and full view of his
staff. Obviously, the Court cannot countenance such
audacious display of depravity on respondent’s part not
only because his obscene habit tarnishes the reputation
of the government agency he works for — the CAAP
where he was engaged at that time as Acting Corporate
Secretary — but also because it shrouds the legal
profession in a negative light. As a lawyer in the
government service, respondent is expected to perform
and discharge his duties with the highest degree of
excellence, professionalism, intelligence, and skill, and
with utmost devotion and dedication to duty.
However, his aforesaid habit miserably fails to showcase
these standards, and instead, displays sheer
unprofessionalism and utter lack of respect to the
government position he was entrusted to hold. His flimsy
excuse that he only does so by himself and that he would
immediately close his laptop whenever anyone would
pass by or come near his table is of no moment, because
the lewdness of his actions, within the setting of this case,
remains.
The legal profession — much more an engagement in the
public service should always be held in high esteem, and
those who belong within its ranks should be unwavering
exemplars of integrity and professionalism. As keepers of
the public faith, lawyers, such as respondent, are
burdened with a high degree of social responsibility and,
hence, must handle their personal affairs with greater
caution. Indeed, those who have taken the oath to assist
in the dispensation of justice should be more possessed of
the consciousness and the will to overcome the weakness
of the flesh, as respondent in this case.
Based on a survey of cases, the recent ruling on the
matter is Cabas v. Sususco, 793 SCRA 309 (2016), which
was promulgated just this June 15, 2016. In the said case,
it was pronounced that: In administrative proceedings,
the quantum of proof necessary for a finding of guilt is
substantial evidence, i.e., that amount of relevant
evidence that a reasonable mind might accept as
adequate to support a conclusion. Further, the
complainant has the burden of proving by substantial
evidence the allegations in his complaint. The basic rule is
that mere allegation is not evidence and is not
equivalent to proof. Charges based on mere suspicion
and speculation likewise cannot be given credence.
(Emphasis supplied)
Accordingly, this more recent pronouncement ought to
control and therefore, quell any further confusion on the
proper evidentiary threshold to be applied in
administrative cases against lawyers.
The evidentiary threshold of substantial evidence — as
opposed to preponderance of evidence — is more in
keeping with the primordial purpose of and essential
considerations attending this type of cases. As case law
elucidates, “[d]isciplinary proceedings against lawyers
are sui generis. Neither purely civil nor purely criminal,
they do not involve a trial of an action or a suit, but is
rather an investigation by the Court into the conduct of
one of its officers. Not being intended to inflict
punishment, it is in no sense a criminal prosecution.
Accordingly, there is neither a plaintiff nor a prosecutor
therein. It may be initiated by the Court motu proprio.
Public interest is its primary objective, and the real
question for determination is whether or not the attorney
is still a fit person to be allowed the privileges as such.
Hence, in the exercise of its disciplinary powers, the Court
merely calls upon a member of the Bar to account for his
actuations as an officer of the Court with the end in view
of preserving the purity of the legal profession and the
proper and honest administration of justice by purging
the profession of members who by their misconduct have
proved themselves no longer worthy to be entrusted with
the duties and responsibilities pertaining to the office of
an attorney. In such posture, there can thus be no
occasion to speak of a complainant or a prosecutor.”
Jurisprudence provides that in similar administrative cases
where the lawyer exhibited immoral conduct, the Court
meted penalties ranging from reprimand to disbarment.
In Advincula v. Macabata, 517 SCRA 600 (2007), the
lawyer was reprimanded for his distasteful act of suddenly
turning the head of his female client towards him and
kissing her on the lips. In De Leon v. Pedreña, 708 SCRA 13
(2013), the lawyer was suspended from the practice of
law for a period of two (2) years for rubbing the female
complainant’s right leg with his hand, trying to insert his
finger into her firmly closed hand, grabbing her hand and
forcibly placed it on his crotch area, and pressing his
finger against her private part. While in Guevarra v. Eala,
529 SCRA 1 (2007), and Valdez v. Dabon, Jr., 775 SCRA 1
(2015), the Court meted the extreme penalty of
disbarment on the erring lawyers who engaged in
extramarital affairs. Here, respondent exhibited his
immoral behavior through his habitual watching of
pornographic materials while in the office and his acts of
sexual harassment against complainant.
Considering the circumstances of this case, the Court
deems it proper to impose upon respondent the penalty
of suspension from the practice of law for a period of two
(2) years.
DOMINADOR P. BURBE VS. ATTY. ALBERTO C. MAGULTA AC
NO. 99-634. JUNE 10, 2002
FACTS:
Petitioner engaged the services of the respondent to
help him recover a claim of money against a creditor.
Respondent prepared demand letters for the petitioner,
which were not successful and so the former intimated
that a case should already be filed. As a result, petitioner
paid the lawyer his fees and included also amounts for
the filing of the case.
A couple of months passed but the petitioner has not yet
received any feedback as to the status of his case.
Petitioner made several follow-ups in the lawyer’s office
but to no avail. The lawyer, to prove that the case has
already been filed even invited petitioner to come with
him to the Justice Hall to verify the status of the case.
Petitioner was made to wait for hours in the prosecutor’s
office while the lawyer allegedly went to the Clerk of
Court to inquire about the case. The lawyer went back to
the petitioner with the news that the Clerk of Court was
absent that day.
Suspicious of the acts of the lawyer, petitioner personally
went to the office of the clerk of court to see for himself
the status of his case. Petitioner found out that no such
case has been filed.
Petitioner confronted Atty. Magulta where he continued
to lie to with the excuse that the delay was being caused
by the court personnel, and only when shown the
certification did he admit that he has not at all filed the
complaint because he had spent the money for the filing
fee for his own purpose; and to appease petitioner’s
feelings, he offered to reimburse him by issuing two (2)
checks, postdated June 1 and June 5, 1999, in the
amounts of P12,000.00 and P8,000.00, respectively.
ISSUE:
 Whether or not the lawyer should be disbarred.
HELD:
Yes. The Supreme Court upheld the decision of the
Commission on Bar Discipline of the IBP as follows: “It is
evident that the P25,000 deposited by complainant with
the Respicio Law Office was for the filing fees of the
Regwill complaint. With complainant’s deposit of the filing
fees for the Regwill complaint, a corresponding
obligation on the part of respondent was created and
that was to file the Regwill complaint within the time
frame contemplated by his client. The failure of
respondent to fulfill this obligation due to his misuse of the
filing fees deposited by complainant, and his attempts to
cover up this misuse of funds of the client, which caused
complainant additional damage and prejudice,
constitutes highly dishonest conduct on his part,
unbecoming a member of the law profession. The
subsequent reimbursement by the respondent of part of
the money deposited by complainant for filing fees, does
not exculpate the respondent for his misappropriation of
said funds.”
IN RE: AL C. ARGOSINO 246 SCRA 14 (1995)
IN MATTER OF THE ADMISSION TO THE BAR AND OATH-
TAKING OF SUCCESSFUL BAR APPLICANT AL C. ARGOSINO
DOCTRINES:
The practice of law is a high personal privilege limited to
citizens of good moral character, with special education
qualifications, duly ascertained and certified.
Requirement of good moral character is of greater
importance so far as the general public and proper
administration of justice is concerned.
All aspects of moral character and behavior may be
inquired into in respect of those seeking admission to the
Bar.
Requirement of good moral character to be satisfied by
those who would seek admission to the bar must be a
necessity more stringent than the norm of conduct
expected from members of the general public.
Participation in the prolonged mindless physical beatings
inflicted upon Raul Camaligan constituted evident
rejection of that moral duty and was totally irresponsible
behavior, which makes impossible a finding that the
participant was possessed of good moral character.
Good moral character is a requirement possession of
which must be demonstrated at the time of the
application for permission to take the bar examinations
and more importantly at the time of application for
admission to the bar and to take the attorney's oath of
office.

FACTS:

On February 4, 1992 ,Argosino, together with 13 others,

was charged with the crime of homicide in connection
with the death of one Raul Camaligan. The death of
Camaligan stemmed from the affliction of severe
physical injuries upon him in course of "hazing" conducted
as part of the university fraternity initiation rites. On
February 11, 1993, the accused were consequently
sentenced to suffer imprisonment for a period ranging
from two (2) years, four (4) months and one (1) day to
four (4) years.

Eleven (11) days later, Mr. Argosino and his colleagues

filed an application for probation with the lower court.
The application was granted on June 18 1993. The period
of probation was set at two (2) years, counted from the
probationer's initial report to the probation officer
assigned to supervise him.

Less than a month later, Argosino filed a petition to take

the bar exam. He was allowed and he passed the exam,
but was not allowed to take the lawyer's oath of office.

On April 15, 1994, Argosino filed a petition to allow him to

take the attorney's oath and be admitted to the practice
of law. He averred that his probation period had been
terminated. It is noted that his probation period did not
last for more than 10 months.

ISSUE:

 Whether Argosino should be allowed to take the

oath of attorney and be admitted to the
practice of law

HELD:

Mr. Argosino must submit to this Court evidence that he

may now be regarded as complying with the
requirement of good moral character imposed upon
those who are seeking admission to the bar. He should
show to the Court how he has tried to make up for the
senseless killing of a helpless student to the family of the
deceased student and to the community at large. In
short, he must show evidence that he is a different person
now, that he has become morally fit for admission to the
profession of law.

He is already directed to inform the Court, by appropriate

written manifestation, of the names of the parents or
brothers and sisters of Camaligan from notice.