RULE 138 OF THE RULES OF COURT courts as to my clients; and I impose upon myself this voluntary
obligation without any mental reservation or purpose of evasion.
Section 1. Who may practice law. - Any person heretofore duly
admitted as a member of the bar, or hereafter admitted as such
in accordance with the provisions of this rule, and who is in good
and regular standing, is entitled to practice law
Sec. 2. Requirements for all applicants for admission to the bar.
- Every applicant for admission as a member of the bar must
be a citizen of the Philippines, at least twenty-one years of age,
of good moral character, and a resident of the Philippines; and
must produce before the Supreme Court satisfactory evidence
of good moral character, and that no charges against him,
involving moral turpitude, have been filed or are pending in any
court in the Philippines. chan robles virtual law library
Sec. 3. Requirements for lawyers who are citizens of the United
States of America. - Citizens of the United States of America
who, before July 4, 1946, were duly licensed members of the
Philippine Bar, in active practice in the courts of the Philippines
and in good and regular standing as such may, upon
satisfactory proof of those facts before the Supreme Court, be
allowed to continue such practice after taking the following oath
of office:
"I, _________________________, having been permitted to
continue in the practice of law in the Philippines, do solemnly
swear that I recognize the supreme authority of the Republic of
the Philippines; I will support its Constitution and obey the laws
as well as the legal orders of the duly constituted authorities
therein; I will do no falsehood, nor consent to the doing of any
in court; I will not wittingly or willingly promote or sue any
groundless, false or unlawful suit, nor give aid nor consent to
the same; I will delay no man for money or malice, and will
conduct myself as a lawyer according to the best of my
knowledge and discretion with all good fidelity as well to the
So help me God."
Sec. 4. Requirements for applicants from other jurisdictions. -
Applicants for admission who, being Filipino citizens, are
enrolled attorneys in good standing in the Supreme Court of the
United States or in any circuit court of appeals or district court
therein, or in the highest court of any State or Territory of the
United States, and who can show by satisfactory certificates
that they have practiced at least five years in any of said courts,
that such practice began before July 4, 1946, and that they have
never been suspended or disbarred, may, in the discretion of
the Court, be admitted without examination.
Sec. 5. Additional requirements for other applicants. - All
applicants for admission other than those referred to in the two
preceding sections shall, before being admitted to the
examination, satisfactorily show that they have regularly studied
law for four years, and successfully completed all prescribed
courses, in a law school or university, officially approved and
recognized by the Secretary of Education. The affidavit of the
candidate, accompanied by a certificate from the university or
school of law, shall be filed as evidence of such facts, and
further evidence may be required by the court.
No applicant shall be admitted to the bar examinations unless
he has satisfactorily completed the following courses in a law
school or university duly recognized by the government: civil
law, commercial law, remedial law, criminal law, public and
private international law, political law, labor and social
legislation, medical jurisprudence, taxation and legal ethics.
chan robles virtual law library
Sec. 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.
Sec. 7. Time for filing proof of qualifications. - All applicants for
admission shall file with the clerk of the Supreme Court the
evidence required by section 2 of this rule at least fifteen (15)
days before the beginning of the examination. If not embraced
within sections 3 and 4 of this rule they shall also file within the
same period the affidavit and certificate required by section 5,
and if embraced within sections 3 and 4 they shall exhibit a
license evidencing the fact of their admission to practice,
satisfactory evidence that the same has not been revoked, and
certificates as to their professional standing. Applicants shall
also file at the same time their own affidavits as to their age,
residence, and citizenship.
Sec. 8. Notice of applications. - Notice of applications for
admission shall be published by the clerk of the Supreme Court
in newspapers published in Pilipino, English and Spanish, for at
least ten (10) days before the beginning of the examination.
Sec. 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 (in Pleading and Conveyancing).
BAR MATTER 1153 (AMENDING SEC 5 & 6 OF RULE 138)
Quoted hereunder, for your information, is a resolution of the
Court En Banc dated March 9, 2010
"B.M. No. 1153 (Re: Letter of Atty. Estelito P. Mendoza
Proposing Reforms in the Bar Examinations Through
Amendments to Rule 138 of the Rules of Court). - The Court
Resolved to APPROVE the proposed amendments to Sections
5 and 6 of Rule 138, to wit:
SEC. 5. Additional Requirement for Other Applicants. — All
applicants for admission other than those referred to in the two
preceding sections shall, before being admitted to the
examination, satisfactorily show that they have successfully
completed all the prescribed courses for the degree of Bachelor
of Laws or its equivalent degree, in a law school or university
officially recognized by the Philippine Government or by the
proper authority in the foreign jurisdiction where the degree has
been granted.
No applicant who obtained the Bachelor of Laws degree in this
jurisdiction shall be admitted to the bar examination unless he
or she has satisfactorily completed the following course in a law
school or university duly recognized by the government: civil
law, commercial law, remedial law, criminal law, public and
private international law, political law, labor and social
legislation, medical jurisprudence, taxation and legal ethics.
A Filipino citizen who graduated from a foreign law school shall
be admitted to the bar examination only upon submission to the
Supreme Court of certifications showing: (a) completion of all
courses leading to the degree of Bachelor of Laws or its
equivalent degree; (b) recognition or accreditation of the law
school by the proper authority; and (c) completion of all the
fourth year subjects in the Bachelor of Laws academic program
in a law school duly recognized by the Philippine Government.
SEC. 6. Pre-Law. — An applicant for admission to the bar
examination shall present a certificate issued by the proper
government agency that, before commencing the study of law,
he or she 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.
A Filipino citizen who completed and obtained his or her
Bachelor of Laws degree or its equivalent in a foreign law school
must present proof of having completed a separate bachelor's
degree course.
The Clerk of Court, through the Office of the Bar Confidant, is
hereby directed to CIRCULARIZE this resolution among all law
schools in the country."
IN THE MATTER OF IBP DUES OF MARCIAL EDILLON
Facts: Marcial A. Edillon is a duly licensed practicing attorney in
the Philippines. Pursuant to the By-Laws of the Integrated Bar
of the Philippines, the IBP recommended the Supreme Court to
remove Edillon’s name from its Roll of Attorneys for refusal to
pay IBP membership dues despite due notice. Atty. Edillon
argued that provisions used as the ground by the IBP constitute
an invasion of his constitutional rights in the sense that he is
being compelled to be a member of the IBP and to pay the
corresponding dues, and that as a consequence of this
compelled financial support of the said organization, he is being
deprived of the rights to liberty and property guaranteed to him
by the Constitution. Hence, concluded that the provisions of the
Court Rule and of the IBP By-Laws are void and of no legal force
and effect.
Issue: Whether or not Atty. Marcial Edillon can be removed from
the Roll of Attorneys for refusing to pay IBP membership dues
despite due notice.
Ratio: Yes. The Integrated Bar is a State-organized Bar which
every lawyer must be a member of as distinguished from bar
associations in which membership is merely optional and
voluntary. Members, thereof, are subject to all the rules
prescribed for the governance of the Bar, including the
requirement of payment for a reasonable annual fee.
Delinquency in paying annual dues will be subject to IBP’s
action, including a recommendation to the Supreme Court for
the suspension of the delinquent member from the practice of
law. In this case, Atty. Edillon became a member of the Bar
when he passed the Bar examinations. Contrary to his
contention, the Bar integration does not compel him to
associate with anyone. He is free to attend or not the meeting
of his Integrated Bar Chapter or vote or refuse to vote in its
election as he chooses. The Rules of Court only compels him
to pay his annual dues and it is not in violation of his
constitutional freedom to associate. Moreover, the Court held
that nothing in the Constitution prohibits the Court from requiring
members of privileged class to pay a reasonable fee to be used
in the regulation of the profession to which they belong. Hence,
the fee is imposed as a regulatory measure, designed to raise
funds for carrying out the objectives and purposes of
integration. Given the Court’s power to promulgate rules
concerning pleadings, practice, and admission to the practice of
law and the integration of the Bar, the Court held that Atty.
Edillon be removed in the Roll of Attorneys due to his stubborn
refusal to pay his membership dues to the IBP.
Held: Edillon is disbarred.
LETTER OF ATTY. AREVALO (2005)
Facts: Atty. Arevalo wrote a letter to the SC requesting for
exemption from payment of his IBP dues from 1977-2005 in the
amount of P12,035.00. He contends that after admission to the
Bar he worked at the Civil Service Commission then migrated
to the US until his retirement. His contention to be exempt is
that his employment with the CSC prohibits him to practice his
law profession and he did not practice the same while in the US.
The compulsion that he pays his IBP annual membership is
oppressive since he has an inactive status as a lawyer. His
removal from the profession because of non-payment of the
same constitutes to the deprivation of his property rights bereft
of due process of the law.
Issues:
1. Is petitioner entitled to exemption from payment of his dues
during the time that he was inactive in the practice of law that
is, when he was in the Civil Service from 1962-1986 and he was
working abroad from 1986-2003?
2. Does the enforcement of the penalty of removal amount to a
deprivation of property without due process?
Held:
1. No. A membership fee in the Bar association is an exaction
for regulation. If the judiciary has inherent power to regulate the
Bar, it follows that as an incident to regulation, it may impose a
membership fee for that purpose. It would not be possible to put
on an integrated Bar program without means to defray the
expenses. The doctrine of implied powers necessarily carries
with it the power to impose such exaction. // The payment of
dues is a necessary consequence of membership in the IBP, of
which no one is exempt. This means that the compulsory nature
of payment of dues subsists for as long as ones membership in
the IBP remains regardless of the lack of practice of, or the type
of practice, the member is engaged in.
2. No. Whether the practice of law is a property right, in the
sense of its being one that entitles the holder of a license to
practice a profession, we do not here pause to consider at
length, as it [is] clear that under the police power of the State,
and under the necessary powers granted to the Court to
perpetuate its existence, the respondents right to practice law
before the courts of this country should be and is a matter
subject to regulation and inquiry. And, if the power to impose
the fee as a regulatory measure is recognize[d], then a penalty
designed to enforce its payment, which penalty may be avoided
altogether by payment, is not void as unreasonable or arbitrary.
// But we must here emphasize that the practice of law is not a
property right but a mere privilege, and as such must bow to the
inherent regulatory power of the Court to exact compliance with
the lawyers public responsibilities. // As a final note, it must be
borne in mind that membership in the bar is a privilege burdened
with conditions, one of which is the payment of membership
dues. Failure to abide by any of them entails the loss of such
privilege if the gravity thereof warrants such drastic move.
1999 BAR EXAMINATIONS, MARK PURISIMA (2002)
BELLOSILLO, J.:
Petitioner was conditionally admitted to take the 1999 Bar
Examinations. Like many others he was directed "to submit the
required certification of completion of the pre-bar review course
within sixty (60) days from the last day of the examinations."
Petitioner passed the 1999 Examinations. But in a Resolution
dated 13 April 2000 the Court disqualified him from becoming a
member of the Philippine Bar and declared his examinations
null and void on two (2) grounds: (a) Petitioner failed to submit
the required certificate of completion of the pre-bar review
course under oath for his conditional admission to the 1999 Bar
Examinations; and (b) He committed a serious act of dishonesty
which rendered him unfit to become a member of the Philippine
Bar when he made it appear in his Petition to Take the 1999 Bar
Examinations that he took his pre-bar review course at the
Philippine Law School (PLS) when, as certified by Acting
Registrar Rasalie G. Kapauan, PLS had not offered such course
since 1967.
Petitioner moved for a reconsideration of the 13 April 2000
Resolution but his motion was denied.
On 29 October 2001, retired Regional Trial Court Judge Amante
P. Purisima, father of petitioner, filed a Petition to Reopen Bar
Matter 986. However, the Court in its Resolution of 27
November 2001 "noted without action" the said petition and
further resolved "that no further pleadings will be entertained."
On 2 July 2002 petitioner filed a Motion for Due Process stating,
among others, his reasons why in his Petition to Take the 1999
Bar Examinations it was stated that he was enrolled in and
regularly attending the pre-bar review course at the PLS and not
at the University of Santo Tomas (UST) where he in fact took
the said course as evidenced by the Certification dated 22 July
1999 of Dean Amado L. Damayuga of the UST Faculty of Civil
Law.
Petitioner claimed that the statement in paragraph 8 of his
Petition that "he . . . enrolled in and passed the regular fourth
year (law) review classes at the Phil. Law School . . ." was a
"self-evident clerical error and a mere result of an oversight
which is not tantamount to a deliberate and willful declaration of
a falsehood."
Petitioner explained that upon obtaining a "ready-made form" of
the Petition and affixing his signature on the space provided
therefor, he requested his schoolmate/friend Ms. Lilian A. Felipe
to fill up the form, have it notarized and then to file it for him with
the Office of the Bar Confidant (OBC). Being "consumed with
his preparations for the upcoming bar examinations," petitioner
admitted that he did not have the opportunity to check the
veracity of the information supplied by Ms. Felipe. Had he done
this he could have readily seen that Ms. Felipe had erroneously
typed "Philippine Law School," instead of UST, on the space
provided for the school where petitioner attended his pre-bar
review course.
Petitioner further averred that on 26 July 1999, a week after the
filing of the Petition to take the bar, he (thru Ms. Felipe)
submitted the Certification of Completion of the Pre-Bar Review
as Annex "D" of his Petition to prove that he actually enrolled
and attended the pre-bar review course in UST.
To corroborate his enrollment in UST, petitioner submitted (a)
the Official Receipt of his payment of tuition fee for the course;
(b) his identification card for the course; (c) car pass to the UST
campus; (d) individual affidavits of classmates in the pre-bar
review course in UST that petitioner was their classmate and
that he attended the review course; (e) separate affidavits of five
(5) UST students/acquaintances of petitioner that they saw him
regularly attending the review lectures; (f) affidavit of Professor
Abelardo T. Domondon attesting to the attendance of petitioner
in his review classes and lectures in Taxation and Bar Review
Methods at the UST Faculty of Civil Law; (g) affidavit of Ms.
Gloria L. Fernandez, maintenance staff at the UST Law
Department that she knew petitioner very well as he was among
those who would arrive early and request her to open the
reading area and turn on the airconditioning before classes
started; and, (h) affidavit of Ms. Melicia Jane Parena, office clerk
at the UST Faculty Civil Law, that Dean Dimayuga issued the
Certification dated 22 July 1999 to the effect that petitioner was
officially enrolled in and had completed the pre-bar review
course in UST which started on 14 April 1999 and ended 24
September 1999.
Petitioner also explained that he did not submit the required
certification of completion of the pre-bar review course within
sixty (60) days from the last day of the examinations because
he thought that it was already unnecessary in view of the
Certification of Completion (Annex "D" of his Petition) issued by
Dean Dimayuga which not only attested to his enrollment in
UST but also his completion of the pre-bar review course.
In a letter dated 17 September 2002, addressed to Chief Justice
Hilario G. Davide, Jr., thru Senior Associate Justice Josue N.
Bellosillo, who took over as Chairman of the 1995 Committee
on Bar Examinations, retired Judge Purisima expressed his
concern for his son and stated that his son took the pre-bar
review course in UST and that the entry in his son’s Petition that
he took it in PLS is a "self-evident clerical error." He then poised
the question that if there was really a falsehood and forgery in
paragraph 8 and Annex "D" of the Petition, which would have
been a fatal defect, why then was his son issued permit to take
the 1999 Bar examinations?
Pursuant to the Court Resolution of 1 October 2002, the OBC
conducted a summary hearing on 30 October 2002 during
which the Bar Confidant asked clarificatory questions from
petitioner who appeared together with his father, retired Judge
Purisima, and Ms. Lilian Felipe.
On 7 November 2002 the OBC submitted its Report and
Recommendation the pertinent portions of which are quoted as
follows: "Considering petitioner’s explanation fortified by
unquestionably genuine documents in support thereof, we
respectfully submit that petitioner should be given the benefit of
the doubt.
The Resolution of the Court dated April 2, 2002, in Bar Matter
890, may be cited. In the said case, Victor Rey T. Gingoyon was
given the benefit of the doubt and allowed to take the Lawyer’s
Oath. Mr. Gingoyon stated in his Petition to take the 1998 Bar
that the charge of Grave Threats (Criminal Case No. 9693)
against him was still pending before the Municipal Trial Courts
in Cities, Mandaue City, Branch 3, when in fact, in the decision
of MTC dated April 8, 1998, he was already convicted. But the
Court believed his explanation that he had no actual knowledge
of his conviction.
In allowing Mr. Gingoyon to take the Lawyer’s Oath, the Court
stated, thus: “It had been two (2) years past since he first filed
the petition to take the lawyer’s oath. Hopefully, this period of
time of being deprived the privilege had been long enough for
him to do some introspection.”
In his letter, petitioner’s father also pleaded that the three (3)
years denial of his son’s request for oath-taking should be
enough penalty, if there may be any wrong that his son may
have unwittingly committed.
It is submitted that the same kindness and compassion
extended to Mr. Gingoyon in Bar Matter 890 be given to
petitioner. Three years deprivation of the privilege to practice
law may be considered an ample penalty, not to mention that
petitioner has not been convicted of any crime.
As regards petitioner’s failure to submit within sixty days the
required certification of completion of the pre-bar review course,
his explanation that there was no need for him to submit another
certification because the July 22, 1999 Certification of Dean
Dimayuga certified not only his enrollment but also his
completion of the course, is impressed with truth.
Let it be also noted that, in the Resolution dated April 13, 2000,
in this Bar Matter 986, the Court declared DISQUALIFIED from
the 1999 Bar examinations not only Purisima but also Josenio
Marquez Reoma, Ma. Salvacion Sucgang Revilla and Victor
Estell Tesorero for their failure to submit within sixty days from
the last day of the examinations the certification of completion
of the pre-bar review course. However, the Court, in its
Resolution dated June 20, 2000, acting on the separate motions
for reconsideration of the Court Resolution dated April 13, 2000
filed by Reoma and Revilla, both were allowed to take the
Lawyer’s Oath.
In the case of Reoma, his explanation that his failure to submit
the required certification was due to his honest belief and
assumption that the UP College of Law, where he took his
review course, had filed the required certification together with
other required documents, was accepted.
In the case of Revilla, her claim that her failure to submit the
required certification within the 60-day period was due to her
erroneous impression that only the certification of enrollment
and attendance was required, was likewise accepted.
The Court also allowed Mr. Tesorero to take his oath, as he
stated that his failure to submit within the 60-day period was due
to his honest and mistaken belief that he had substantially
complied with the requirements for admission to the Bar
Examinations because he thought that the required certificate
of completion of the pre-bar review course is the same as the
certificate of enrollment and attendance in the said course.
The OBS respectfully submits that petitioner’s explanation
should also be given credit just like his three co-examinees.
Let it be finally cited that in Bar Matter No. 832, in the Matter of
Admission to the Bar of Blas Antonio M. Tuliao, the Court also
favorably considered the report of the Committee on Legal
Education which recommended the admission to the Bar of Mr.
Tuliao on grounds of fairness, equal treatment and protection,
considering that his co-accused in a criminal case have been
allowed to take the lawyer’s oath. This Court stated, in its
Resolution dated November 27, 2001, that there was no reason
to accord a different treatment to Mr. Tuliao, and that the
dispensation of justice should be even-handed and consistent."
The recommendation is well taken.
The foremost question to be resolved is whether petitioner did
enroll in and complete his pre-bar review course in UST as he
herein avows.
The testimony of petitioner and Ms. Felipe during the 30
October 2002 hearing that the subject Certification of Dean
Dimayuga was duly submitted to the OBC a week after the filing
of the Petition to take the bar appears to be credible. It is
supported by documentary evidence showing that petitioner
actually enrolled and completed the required course in UST.
Granting that the Certification of Dean Dimayuga was defective
as it certified completion of the pre-bar review course which was
still on-going, this defect should not be attributed to petitioner
considering that he had no participation in the preparation
thereof. Whatever it is, the fact remains that there is such a
certification issued by the UST which appears to be genuine.
This finding is backed by the affidavit of Ms. Parena, office clerk
at the UST Faculty of Civil Law, that she was the one who
released the Certification to petitioner on 26 July 1999.
Indeed, it must be stressed that there is nothing on record which
impugns the authenticity of the subject Certification as well as
that of the other documentary evidence proffered by petitioner
to establish that he was duly enrolled and took the pre-bar
review course in UST, not in PLS. As to the argument that the
Certification of Dean Dimayuga did not include the "taking and
completion" of the pre-bar review course, the realities of our bar
reviews render it difficult to record the attendance religiously of
the reviewees every single day for several months.
Considering petitioner’s explanation, fortified by undisputedly
genuine documents, at the very least, petitioner should be given
the benefit of the doubt and be allowed to take his oath.
The Court is well aware of instances in the past when, as a
measure of compassion and kindness, it has acted favorably on
similar petitions. In his letter petitioner’s father pleaded that "the
denial of permission for Mark to take his oath for about three (3)
years now should be enough penalty." It is time to move on.
At this juncture it may be well to note the Court’s growing
concern over the apparent laxity of law schools in the conduct
of their pre-bar review classes. Specifically, it has been
observed that the attendance of reviewees is not closely
monitored, such that some reviewees are able to comply with
the requisite with minimal attendance. Enrollment and
completion of pre-bar review course is an additional
requirement under Rule 138 of the Rules of Court for those who
failed the bar examinations for three (3) or more times.
For the Court to insist on strict compliance may be literally
asking for the moon but it can be done. We just have to bear in
mind that this requirement is not an empty or idle ceremony; it
is intended to ensure the quality and preparedness of those
applying for admission to the bar.
WHEREFORE, premises considered, as recommended by the
Office of the Bar Confidant in its Report and Recommendation
dated 7 November 2002, the prayer in Bar Matters Nos. 979
and 986 is granted and examinee MARK ANTHONY A.
PURISIMA who passed the 1999 Bar Examinations is now
allowed to take the Lawyer’s Oath and be admitted to the
Philippine Bar. He is further allowed to sign the Roll of Attorneys
upon payment of the required fees.
AGUIRRE VS RANA, BM 1036 (2003)
Facts: Rana was among those who passed the 2000 Bar
Examinations. before the scheduled mass oath-taking,
complainant Aguirre filed against respondent a Petition for
Denial of Admission to the Bar.
The Court allowed respondent to take his oath. Respondent
took the lawyer’s oath on the scheduled date but has not signed
the Roll of Attorneys up to now.
Complainant alleges that respondent, while not yet a lawyer,
appeared as counsel for a candidate in an election.
On the charge of violation of law, complainant claims that
respondent is a municipal government employee, being a
secretary of the Sangguniang Bayan of Mandaon, Masbate. As
such, respondent is not allowed by law to act as counsel for a
client in any court or administrative body.
On the charge of grave misconduct and misrepresentation,
complainant accuses respondent of acting as counsel for vice
mayoralty candidate George Bunan without the latter engaging
respondent’s services. Complainant claims that respondent
filed the pleading as a ploy to prevent the proclamation of the
winning vice mayoralty candidate.
Issue: Whether or not respondent engaged in the unauthorized
practice of law and thus does not deserve admission to the
Philippine Bar
Ratio: The Court held that “practice of law” means any activity,
in or out of court, which requires the application of law, legal
procedure, knowledge, training and experience. To engage in
the practice of law is to perform acts which are usually
performed by members of the legal profession. Generally, to
practice law is to render any kind of service which requires the
use of legal knowledge or skill.
The right to practice law is not a natural or constitutional right
but is a privilege. It is limited to persons of good moral character
with special qualifications duly ascertained and certified. The
exercise of this privilege presupposes possession of integrity,
legal knowledge, educational attainment, and even public trust
since a lawyer is an officer of the court. A bar candidate does
not acquire the right to practice law simply by passing the bar
examinations. The practice of law is a privilege that can be
withheld even from one who has passed the bar examinations,
if the person seeking admission had practiced law without a
license.

True, respondent here passed the 2000 Bar Examinations and

took the lawyer’s oath. However, it is the signing in the Roll of
Attorneys that finally makes one a full-fledged lawyer. The fact
that respondent passed the bar examinations is immaterial.
Passing the bar is not the only qualification to become an
attorney-at-law. Respondent should know that two essential
requisites for becoming a lawyer still had to be performed,
namely: his lawyer’s oath to be administered by this Court and
his signature in the Roll of Attorneys.

(DISCLAIMER: the content of this compilation is not mine.

i just got it online hehe. hope this helps us all -freeds <3)