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B.M. No. 1678 Dec.

Dec. 17, 2007 The Constitution also provides that the practice of all  Deceit – for falsely representing herself to be
professions in the Philippines shall be limited to married to Felicisimo Tenorio, Jr. who has a
Petition for Leave to Resume Practice of Law Filipinos. prior and subsisting marriage with another
Benjamin M. Dacanay, petitioner woman and were able to obtain a false
Since it is a requirement for admission to the bar, loss marriage contract (February 10, 1980 in
Facts: therefore terminates membership in the Philippine Bar Manila same date with their 2 children’s birth
& consequently the privilege to engage in the practice certificate). No record exist in NSO and Civil
 Petitioner was admitted to the Bar in March of law. Registry. In BC of their other 2 children,
1960. another date and place of marriage are
Exception: When a Filipino citizenship is lost by
 He practiced law until he migrated to Canada indicated (February 12, 1980 in Malaybalay,
reason of naturalization as a citizen of another country
in December 1998 to seek medical attention for Bukidnon)
but subsequently reacquired pursued to RA 9225. “All
his ailments.
Philippine citizens who become citizens of another  Grossly Immoral Conduct – dissemination to
 He applied for Canadian citizen to avail the public of libellous affidavit derogatory to
country shall be deemed not to have lost their
Canada’s free medical aid program. His Makati Councilor Jacome.
Philippine citizenship under the conditions of RA
application was approved on May 2004.
9225”  Malpractice & Other Gross Misconduct –
 On July 14, 2006, pursuant to RA 9225 1
Respondent cooperated in the illegal practice
(Citizen Retention & Reacquisition Act of Although petitioner is also deemed never to have of law by her husband, who is not a member of
2003), petitioner acquired his Philippine terminated his membership in the Philippines bar, no the Philippine Bar; 2converted his clients’
citizenship. automatic right to resume law practice accrues. money to her own use & benefit which led to
 He took his oath of allegiance as a Filipino an estafa case against her; & 3threatened the
citizen before the Philippine Consulate General He must first secure from this court the authority to do complainant & her family with the statement
in Toronto, Canada. so, conditioned on: “isang bala ka lang” to deter them from
 Thereafter, he returned to the Philippines and divulging respondent’s illegal activities &
1. Updating & payment in full of the annual
now intends to resume his law practice. transactions.
membership dues in IBP
2. Payment of Professional tax  Respondent denied all allegations.
Issue:
3. Completion of at least 36 credit hours of
WON petitioner may resume his practice of law upon mandatory continuing legal application
reacquisition of Philippine citizenship. 4. Retaking of Lawyer’s oath

Ruling: Compliance with these conditions & submission of


proof of such compliance to the Bar Confidant.
Yes. SC approved the recommendation of the Office of
the Bar Confidant with certain modifications. PETITION GRANTED.

The practice of law is a privilege burdened with He submitted a copy of his ID Cert. No. duly signed by
conditions. Immigration Commissioner Libanan.

Sec. 2, Rule 138, Rules of Court A.C. 6290 July 14, 2004
Every applicant for admission as a member of the Anna Marie Cambaliza, petitioner vs. Ana Luz
bar must be a citizen of the Philippines, at least Cristal – Tenorio, respondent
twenty-one years of age, of good moral character, and a
resident of the Philippines; and must produce before the Facts:
Supreme Court satisfactory evidence of good moral
character, and that no charges against him, involving  Complainant is a former employee of
moral turpitude, have been filed or are pending in any respondent in her law office, who charged the
court in the Philippines. latter with: