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Requirements to Practice Law

IBP Membership
Detention
IBP Dues
Citizenship
Zeta vs. Malinao
A.M. No. P-220
December 20, 1978
IBP Membership
Felicisimo Malinao
Court interpreter in the CFI of Catbalogan, Samar
Administrative complaint
Julio Zeta
Resident of Zumarraga, Samar
Fictitious person
What did Malinao do?
Illegally appearing in court
Grave misconduct in office
Crime of falsification
Violation of executive order and civil service law
Illegally appearing in court
Judge Restituto Duran of Sta. Rita, Samar, declared that according to his docket
books the respondent appeared as counsel for Vicente Baculanlan in criminal
case No. 1247 in the Municipal Court of Sta. Rita, Samar, for grave threats and
in criminal case No. 1249 for the same accused and Romulo Villagracia for
illegal possession of firearm on August 5, 1960 and on September 17, 1970.
Judge Miguel Avestruz of Daram, Samar, declared that the respondent
appeared as counsel in civil case No. 39 in the Municipal Court of Daram,
Samar, entitled Felix Versoza versus Victor Payao, et al., for forcible entry on
December 15, 1962, January 26, 1963, February 18, 1963 and on March 1,
1963.
Judge Juanito Reyes declared that on March 27, 1969, the respondent appeared
as counsel for the defendant in civil case No. 318 of the Municipal Court of
Zumarraga entitled Restituto Centino versus Jesus Tizon for forcible entry and
again on June 17, 1970 in the same case.
Falsification (Time Records)
He made it appear that on December 15, 1962 and February 18,
1963 he was present in his office although according to the
testimony of Judge Miguel Avestruz he was before his Court on
December 15, 1962 as well as on February 18, 1963.
According to Judge Juanito Reyes the respondent appeared in his
Court on June 17, 1970. The respondent again made it appear in
his daily time record that he was present with an undertime of
five hours. The respondent did not offer any plausible explanation
for this irregularity.
He had made it appear that he was present in his office on
December 15, 1962, February 18, 1963 and June 17, 1970 when
as a matter of fact he was in the Municipal Court of Daram.
Violation of executive order and civil service law

Violation of Section 12, Rule XVIII, Republic Act 2260, as


amended
Respondent had been appearing as counsel in the
municipal courts of Sta. Rita, Daram and Zumarraga in
violation of the rules of the Civil Service Law
Defense
Malinaos participation for defendants' cause was
gratuitous as they could not engage the services of
counsel by reason of poverty and the absence of one in
the locality, said assistance has also checked the
miscarriage of justice by the Presiding Municipal Judge,
now resigned
Concluding the Investigation
The Inquest Judge recommended that he be given stern
warning and severe reprimand
The Court carefully reviewed the records; Amply
supported by evidence
Adopted the findings of the investigator
Issue
Is there an illegal practice of law?
Ruling
YES
His defense is not valid, even if true, considering that in
appearing as counsel in court, he did so without permission from
his superiors and, worse, he falsified his time record of service to
conceal his absence from his office on the dates in question
The number of times that respondent acted as counsel under
the above circumstances would indicate that he was doing it as a
regular practice obviously for considerations other than pure love
of justice
Removal from service, with the admonition that he desist from
appearing in any court or investigative body wherein only
members of the bar are allowed to practice
Grounds
Appearing as counsel in various municipal courts
without prior permission of his superiors in violation
of civil service rules and regulations
Falsified his time record of service by making it appear
therein that he was present in his office on occasions
when in fact he was in the municipal courts appearing
as counsel
Not being a member of the bar
People vs.
Maceda and Javellana
G.R. Nos. 89591-96
January 24, 2000
Detention
Parties
Respondent Judge Bonifacio Sanz Maceda
Private respondent Avelino T. Javellana
People of the Philippines
The Trial Courts Order (Judge
Maceda)
An order of the trial court dated August 8, 1989 gave custody over
private respondent Avelino T. Javellana to the Clerk of Court of the
Regional Trial Court, Branch 12, San Jose, Antique, Atty. Deogracias
del Rosario, during the pendency of Criminal Cases Nos. 3350-3355
No grave abuse of discretion
private respondent informed the court that there exists a real
and grave danger to his life if he were to be confined in the Antique
Provincial Jail (G.R. No. 89591-96; August 13, 1990)
The order specifically provided for private respondents detention at
the residence of Atty. del Rosario; private respondent was not to be
allowed liberty to roam around, but was to be held as detention
prisoner in said residence
What Really Happened
Order of the trial court was not strictly complied with
Private respondent was not detained in the residence of
Atty. Del Rosario
He went about his normal activities as if he were a free
man, including engaging in the practice of law
He continued to accept cases and continued practicing
law
Senior State Prosecutor Henrick F.
Guingoyons Motion filed with the
SC
Does the resolution of this Honorable Court dated July 30, 1990, prohibiting
Atty. Javellana from appearing as counsel refer only to Criminal Case No.
4262?
[ During the pendency of G. R. No. 89591-96, on July 16, 1990, private respondent
Avelino T. Javellana filed a motion seeking permission from this Court to be allowed to
appear as counsel for accused Norberto Patino in Criminal Case No. 4262, then pending
before Regional Trial Court, Branch 12, San Jose, Antique. This Court denied his
motion and ruled that being a detention prisoner, he cannot be allowed to appear as
counsel for the aforesaid accused. ]
Is Atty. now (Judge) Deogracias del Rosario still the custodian of Atty.
Javellana?
Since it appears that Atty. (now Judge) del Rosario never really held and
detained Atty. Javellana as prisoner in his residence, is not Atty. Javellana
considered an escapee or a fugitive of justice for which warrant for his arrest
should forthwith be issued?
Re: Custodianship
The trial court gave Atty. Deogracias del Rosario the
custody of private respondent Javellana
with the obligation "to hold and detain" him in Atty.
del Rosarios residence in his official capacity as the
clerk of court of the regional trial court.
When Atty. del Rosario was appointed judge, he ceased
to be the personal custodian of accused Javellana
The succeeding clerk of court must be deemed the
custodian under the same undertaking
Re: Scope of the Courts Resolution
The trial courts order was clear that private respondent
"is not to be allowed liberty to roam around but is to be
held as a detention prisoner."
The prohibition to practice law referred not only to
Criminal Case No. 4262, but to all other cases as well,
except in cases where private respondent would appear
in court to defend himself.
Solution
In our mind, the perceived threats to private respondent
Javelanas life no longer exist; thus, the trial courts order
giving custody over him to the clerk of court must be recalled
He shall be detained at the Provincial Jail of Antique at San
Jose, Antique.
All the accused in Criminal Cases Nos. 3350-3355 must be
confined in the Provincial Jail of Antique.
Continue with the trial of said criminal cases with all
deliberate dispatch and to avoid further delay, considering
that the criminal cases have dragged on for more than 10
years
Main Issue
Whether or not the respondent may continue to practice
his legal profession, being a detention prisoner.
Ruling
NO
As a detention prisoner, private respondent Javellana is not allowed
to practice his profession, as a necessary consequence of his
status as a detention prisoner
All prisoners whether under preventive detention or serving
final sentence can not practice their profession nor engage in any
business or occupation, or hold office, elective or appointive, while
in detention
All accused in the case are ordered detained at the Provincial Jail of
Antique, San Jose, Antique, effective immediately, and shall not be
allowed to go out of the jail for any reason or guise, except upon
prior written permission of the trial court for a lawful purpose.
Santos, Jr. vs. Atty.
Llamas
A.C No. 4749
January 20, 2000
IBP Dues
Parties
Complainant Atty. Soliman M. Santos, Jr.
Respondent Atty. Francisco R. Llamas
Complaint
Atty. Llamas, for a number of years now, has not indicated the
proper PTR and IBP O.R. Nos. and data (date & place of
issuance) in his pleadings. If at all, he only indicates "IBP Rizal
259060" but he has been using this for at least three years
already
While Atty. Llamas indicates IBP Rizal 259060, sometimes, he
does not indicate any PTR for payment of professional tax
Dismissed from position as Pasay City Judge (A.M. No. 1037-CJ)
Convicted for estafa (Crim. Case No. 11787, Makati)
Clarification and appropriate action on the bar standing of Atty.
Llamas with both the Bar Confidant and the IBP
Pertinent Provisions
Rules of Court, Rule 138, 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.
Rules of Court, Rule 139-A, Sec. 9. Membership dues. - Every member of the
Integrated Bar shall pay such annual dues as the Board of Governors shall
determine with the approval of the Supreme Court. A fixed sum equivalent to
ten percent (10%) of the collections from each Chapter shall be set aside as a
Welfare Fund for disabled members of the Chapter and the compulsory heirs of
deceased members thereof.
Rules of Court, Rule 139-A, Section 10. Effect of non-payment of dues.
Subject to the provisions of Section 12 of this Rule, default in the payment of
annual dues for six months shall warrant suspension of membership in the
Integrated Bar, and default in such payment for one year shall be a ground for
the removal of the name of the delinquent member from the Roll of Attorneys.
Pertinent Provisions (Re: Copies)
Rules of Court, Rule 138, Section 27. Attorneys removed or suspended by
Supreme Court on what grounds. A member of the bar may be removed or
suspended from his office as attorney by the Supreme Court for any deceit,
malpractice, or other gross misconduct in such office, grossly immoral conduct, or
by reason of his conviction of a crime involving moral turpitude, or for any violation
of the oath which he is required to take before the admission to practice, or for a
wilfull disobedience of any lawful order of a superior court, or for corruptly or willful
appearing as an attorney for a party to a case without authority so to do. The
practice of soliciting cases at law for the purpose of gain, either personally or
through paid agents or brokers, constitutes malpractice.
Rules of Court, Rule 138, Section 28. Suspension of attorney by the Court of
Appeals or a Court of First Instance. The Court of Appeals or a Court of First
Instance may suspend an attorney from practice for any of the causes named in
the last preceding section, and after such suspension such attorney shall not
practice his profession until further action of the Supreme Court in the premises.
Findings
On April 18, 1997, complainant filed a certification
dated March 18, 1997, by the then president of the
Integrated Bar of the Philippines, Atty. Ida R. Macalinao-
Javier, that respondents "last payment of his IBP dues
was in 1991.
Since then he has not paid or remitted any amount to
cover his membership fees up to the present.
He was using in 1995, 1996 and 1997 the same O.R. No.
259060 of the Rizal IBP; he is automatically no longer a
member in good standing, in relation to Rule 138,
Section 1.
Defenses
The Supreme Court dismissal decision was set aside and reversed and
respondent was even promoted from City Judge of Pasay City to Regional Trial
Court Judge of Makati, Br. 150; the decision in the estafa case was appealed to
the Court of Appeals and is still pending
Respondent, since 1992, had publicly made it clear per his Income Tax Return,
up to the present, that he had only a limited practice of law, and his
principal occupation is farmer (30-hectare orchard and pineapple farm in
Calauan, Laguna)
Senior Citizen since 1992, is legally exempt (under Section 4 of Rep. Act 7432
which took effect in 1992) from the payment of taxes, such as income tax
Being thus exempt, he honestly believe in view of his detachment from a
total practice of law, but only in a limited practice, the subsequent payment by
him of dues with the Integrated Bar is covered by such exemption. In fact, he
never exercised his rights as an IBP member to vote and be voted upon.
Issue
Does Atty. Llamas need to pay his IBP dues?
Whether or not Atty. Llamas is guilty of violating the
Code of Professional Responsibility.
Ruling IBP Dues
YES
Rules of Court, Rule 139-A, Sections 9 and 10
IBP Board of Governors adopted and approved the report and
recommendation of the Investigating Commissioner
Suspension from the practice of law for three months and until he
pays his IBP dues
RA 7432s exemptions do not apply to IBP dues. Therefore, he is
not exempt.
Respondent can engage in the practice of law only by paying his
dues.
It does not matter that his practice is "limited."
Pertinent Provisions
Rules of Court, Rule 138, 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.
Rules of Court, Rule 139-A, Sec. 9. Membership dues. - Every member of the
Integrated Bar shall pay such annual dues as the Board of Governors shall
determine with the approval of the Supreme Court. A fixed sum equivalent to
ten percent (10%) of the collections from each Chapter shall be set aside as a
Welfare Fund for disabled members of the Chapter and the compulsory heirs of
deceased members thereof.
Rules of Court, Rule 139-A, Section 10. Effect of non-payment of dues.
Subject to the provisions of Section 12 of this Rule, default in the payment of
annual dues for six months shall warrant suspension of membership in the
Integrated Bar, and default in such payment for one year shall be a ground for
the removal of the name of the delinquent member from the Roll of Attorneys.
Ruling IBP Dues (contd.)
While it is true that R.A. No. 7432, 4 grants senior
citizens "exemption from the payment of individual
income taxes: provided, that their annual taxable
income does not exceed the poverty level as
determined by the National Economic and Development
Authority (NEDA) for that year," the exemption does not
include payment of membership or association dues.
Ruling CPR Violations
YES
By indicating "IBP-Rizal 259060" in his pleadings and
thereby misrepresenting to the public and the courts
that he had paid his IBP dues to the Rizal Chapter
Pertinent Provisions CPR
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. Esmso
CANON 10 - A LAWYER OWES CANDOR, FAIRNESS AND
GOOD FAITH TO THE COURT.
Rule 10.01 - A lawyer shall not do any falsehood, nor
consent to the doing of any court; nor shall he mislead or
allow the court to be misled by any artifice.
Ruling
Respondents failure to pay his IBP dues and his
misrepresentation in the pleadings he filed in court
indeed merit the most severe penalty.
However, in view of respondents advanced age, his
express willingness to pay his dues and plea for a more
temperate application of the law, we believe the penalty
of one year suspension from the practice of law or until
he has paid his IBP dues, whichever is later, is
appropriate.
Petition for leave to
resume practice of law
BENJAMIN M. DACANAY, petitioner.
B.M. No. 1678
December 17, 2007
Citizenship
Benjamin M. Dacanay
Admitted to the Philippine bar in March 1960 and practiced law
Migrated to Canada in December 1998 to seek medical attention
for his ailments
Applied for Canadian citizenship to avail of Canadas free medical
aid program (Approved!)
Became a Canadian citizen in May 2004
Reacquired Philippine citizenship in July 2006, wherein he took
his oath of allegiance as a Filipino citizen before the Philippine
Consulate General in Toronto, Canada
Returned to the Philippines and now intends to resume his law
practice.
R.A. 9225
Citizenship Retention and Re-acquisition Act of 2003
Section 2. Declaration of Policy - It is hereby
declared the policy of the State that all Philippine
citizens of another country shall be deemed not to have
lost their Philippine citizenship under the conditions of
this Act.
Section 3. Retention of Philippine Citizenship - Any
provision of law to the contrary notwithstanding,
natural-born citizenship by reason of their naturalization
as citizens of a foreign country are hereby deemed to
have re-acquired Philippine citizenship upon taking the
following oath of allegiance to the Republic: xxx
Issue
Whether or not petitioner Benjamin M. Dacanay lost his
membership in the Philippine bar when he gave up his
Philippine citizenship in May 2004.
Ruling
NO..?
Although he is also deemed never to have terminated
his membership in the Philippine bar, no automatic
right to resume law practice accrues.
If a person intends to practice the legal profession in the
Philippines and he reacquires his Filipino citizenship
pursuant to RA 9225, he shall apply with the proper
authority for a license or permit to engage in such
practice
R.A. 9225
Section 5. Civil and Political Rights and Liabilities - Those who
retain or re-acquire Philippine citizenship under this Act shall enjoy full
civil and political rights and be subject to all attendant liabilities and
responsibilities under existing laws of the Philippines and the following
conditions:
(1) xxx
(2) xxx
(3) xxx
(4) Those intending to practice their profession in the Philippines shall
apply with the proper authority for a license or permit to engage in
such practice
(5) xxx
General Rule (PH Constitution)
The practice of law is a privilege denied to foreigners
Filipino citizenship is a requirement for admission to the
bar
Loss of citizenship terminates membership in the
Philippine bar, and, consequently, the privilege to
engage in the practice of law
The loss of Filipino citizenship ipso jure terminates the
privilege to practice law in the Philippines
Exception (R.A. 9225)
When Filipino citizenship is lost by reason of
naturalization as a citizen of another country but
subsequently reacquired pursuant to RA 9225
Section 2: all Philippine citizens who become citizens
of another country shall be deemed not to have lost
their Philippine citizenship under the conditions of RA
9225
Section 4 requirements
Requirements to Restore Good
Standing
Updating and payment in full of the annual IBP
membership dues
Payment of professional tax
Completion of at least 36 credit hours of mandatory
continuing legal education*
Retaking of the lawyers oath**

* This is specially significant to refresh the applicant/petitioners knowledge of


Philippine laws and update him of legal developments
** Which will not only remind him of his duties and responsibilities as a lawyer
and as an officer of the Court, but also renew his pledge to maintain allegiance
to the Republic of the Philippines
Petition to re-acquire the
privilege to practice law in
the philippines
EPIFANJO B. MUNESES, petitioner.
B.M. No. 2112
July 24, 2012
Standard Requirements, in rel. to Re-acquired Citizenship
Epifanio B. Muneses
Member of the Philippine Bar
Became a citizen of the United States of America on
August 28, 1981
Reacquired his Philippine citizenship pursuant to RA
9225 on September 15, 2006
Intends to retire in the Philippines, and if granted, to
resume the practice of law
Support
Oath of Allegiance dated September 15, 2006 before
Consul General Domingo P. Nolasco
Petition for Re-Acquisition of Philippine Citizenship of same
date
Order for Re-Acquisition of Philippine Citizenship also of
same date
Letter dated March 13, 2008 evidencing payment of
membership dues with the IBP
Attendance Forms from the Mandatory Continuing Legal
Education (MCLE)
Dacanay Case
The right to resume the practice of law is not
automatic.
Rationale
The practice of law is a privilege burdened with
conditions.
It is so delicately affected with public interest that it is
both the power and duty of the State (through this
Court) to control and regulate it in order to protect and
promote the public welfare.
Issue
Can Atty. Muneses return to the practice of law in the
Philippines?
Ruling
YES
Dacanay case
Ruling
Adherence to rigid standards of mental fitness,
maintenance of the highest degree of morality, faithful
observance of the legal profession, compliance with
the mandatory continuing legal education
requirement and payment of membership fees to the
Integrated Bar of the Philippines(IBP) are the
conditions required for membership in good standing
in the bar and for enjoying the privilege to practice law
Any breach by a lawyer of any of these conditions
makes him unworthy of the trust and confidence which
the courts and clients repose in him for the continued
exercise of his professional privilege
Requirements
1. Petition for Re-Acquisition of Philippine Citizenship;
2. Order (for Re-Acquisition of Philippine citizenship);
3. Oath of Allegiance to the Republic of the Philippines;
4. Identification Certificate (IC) issued by the Bureau of
Immigration;
5. Certificate of Good Standing issued by the IBP;
6. Certification from the IBP indicating updated payments of
annual membership dues;
7. Proof of payment of professional tax; and,
8. Certificate of compliance issued by the MCLE Office.
Ending
Muneses submitted the remaining requirements
The Office of the Bar Confidant recommended that the
petitioner be allowed to resume his practice of law
The Court adopted the recommendation and saw no bar to
the petitioner's resumption to the practice of law in the
Philippines, after retaking the Lawyers Oath and payment
of appropriate fees
Furthermore, the Office of the Bar Confidant is directed to
draft the necessary guidelines for the re-acquisition of the
privilege to resume the practice of law for the guidance of
the Bench and Bar.
People vs. De Luna, et
al.
G.R. Nos. L-10236-48
January 31, 1958
Bar Flunkers Petition
Bar Flunkers Act of 1953
unconstitutional and therefore void and without force and
effect (Cunanan case*)
Accused of contemptuously disobeying the Supreme Court
Resolution, obstructing or degrading the administration of
justice, and disrespecting the Court
Pedro B. Ayudas Manifestation to the Supreme Court

*In the Matter of Petitions for Admission to the Bar of Unsuccessful Candidates (1946-1953); CUNANAN
In-re attorneys who took the oath before a Notary
Public under the provisions of Republic Act No. 972
Oreste Arellano y Rodriguez.
Pedro B. Ayuda.
Alawadin I. Bandon.
Roque J. Briones.
Abraham C. Calaguas.
Balbino P. Fajardo.
Claro C. Gofredo.
Estela R. Gordo.
Generoso H. Hubilla.
Emilio P. Jardinico, Jr.
Angelo T. Lopez.
Eustacio de Luna.
Jaime P. Marco.
Santos L. Parina.
Florencio P. Sugarol, and
Maria Velez y Estrellas.
Attorneys.
Manifestation
COMES NOW the undersigned for and in representation of the above-named
attorneys and to this Honorable Court, hereby respectfully makes
manifestation that they have taken the oath of office as Attorneys-at-Law on
December 22, 1954 before Mr. Anatolio A. Alcova, a Notary Public in and for
the City of Manila, with office at R-201 Regina Building, Escolta, Manila, in
pursuance of the provisions of Republic Act No. 972;
Messrs, Alejandro P. Capitulo, Claro C. Godofredo, and Florencio P. Sugarol of
the group took the bar examination in August, 1954. They also had taken
their oath before this Honorable Tribunal, January 20, 1955.
This manifestation is made for all legal effects as they will practice law in all
the Courts of the Philippines. [Manila, Philippines, January 28, 1955.]
(Sgd.) PEDRO B. AYUDA; In his own behalf and on behalf of the others in his
capacity as president of the 1946-1952 BAR EXAMINEES ASSOCIATION, 2034
Azcarraga, Manila.
Facts
Appellees knew that they did not pass the bar
examination
They were notified of the resolution of the Supreme
Court denying their petition.
The resolution denying the petition of appellees
necessarily implied a denial of the right to said oath. It
also served as a prohibition of against the taking
thereof.
Nevertheless, appellees took the oath before a notary
public, and formally advised the Supreme Court that
they will practice in all the courts of the Philippines, in
clear violation of the Resolution of the Supreme Court.
Issue Contempt
Whether or not the appellees contemptuously
disobeyed the Supreme Court Resolution, obstructed or
degraded the administration of justice, and disrespected
the Court.
Ruling Contempt
YES
By their act of taking the oath of office and notifying the
Supreme Court of the same and that they would "practice law in
all courts of the Philippines", the appellees had presented
themselves as such attorneys-at-law, in clear contempt of
the order issued by the Court
The appellees overtly challenged and defied the authority of the
Supreme Court to decide upon the issue of admission. Moreover,
they embarrased, hindered and obstructed the administration of
justice and disrespected the courts of justice, especially the
Supreme Court., qualified as contemptuous acts under section
3(b) Rule 64 of the Rules of Court
Ruling Contempt
They performed acts constituting an "improper
conduct tending, directly or indirectly, to impede,
obstruct, or degrade the administration of
justice," in violation of section 3, subdivision (b) of said
Rule 64.
. . . Acts which bring the court into disrepute or
disrespect or which offend its dignity, affront its
majesty, or challenge its authority constitute contempt
of court. . . . (12 Am. Jur. 395.).
Issue Jurisdiction (CFI)
The case was filed before the Court of First Instance of
Manila.
However, the lower court ruled that it had no
jurisdiction to try the case as the contempt was not
committed against it but against the Supreme Court.
The CFIs decision was anchored on Rule 64 Section 4 of
the Rules of Court and Corpus Juris Secundum: Where
the contempt . . . has been committed against a
superior court or judge, or against an officer appointed
by it, the charge may be filed with such superior court.
SC Ruling Jurisdiction
Merely permissive in nature
Merely declaratory of the inherent power of the courts
to punish those guilty of contempt against it
The jurisdiction of the court to punish contempt is not
exclusive
The Supreme Court has no authority to exercise such
denial
To put it differently, the acts charged were committed,
according to said amended information, in contempt of
the Supreme Court, as well as of "all other courts of the
Philippines," including the Court of First Instance of
Resolutions
It appearing that the defendants, except Capitulo, Gefredo, and
Sugarol, have not passed the examinations, it was resolved:
A. To refer the matter to the Fiscal, City of Manila for investigation and appropriate
action in connection with Section 3 (e), Rule 64;
B. As Pedro Ayuda has assumed to be an attorney without authority, he is given 10
days from notice thereof, within which to explain why he should not be dealt with
for contempt of the Court;
C. The notary public Anatolio A. Alcoba, member of the Bar, who has illegally
administered the oath to the said persons in disregard of this Court's resolution
denying them admission to the Bar (except Capitulo, Gofredo and Sugarol), is hereby
given ten days to show cause why he should not be disbarred or suspended from
the pratice of law;
D. The clerk of Court is directed to furnish copy of this resolution to the Court of
Appeals and to all courts of first instance, the Court of Industrial Relations, the
Public Service Commission, and the Department of Justice;
E. As to Capitulo, Gofredo and Sugarol, proper action will be taken later in their
respective cases. (pp. 36-37, rec., G.R. No. L-10245.)