The Supreme Court has decided five cases regarding the Admission to or

the continuing admission to the Bar with regards to Moral Coduct.

In the case of Figuroa vs Barranco, the supreme court ruled that mere
intimacy between a man and a woman, both of whom possess no impediment
to marry, voluntarily carried on and devoid of any deceit on the part of
respondent, is neither so corrupt nor so unprincipled as to warrant the
imposition of disciplinary sanction against him, even if as a result of such
relationship a child was born out of wedlock.
WHEREFORE, the instant petition is hereby DISMISSED. Respondent
Simeon Barranco, Jr. is ALLOWED to take his oath as a lawyer upon payment
of the proper fees.
In the case of Arciga vs Maniwag, the supreme court ruled If good
moral character is a sine qua non for admission to the bar, then the continued
possession of good moral character is also a requisite for retaining membership
in the legal profession. Membership in the bar may be terminated when a
lawyer ceases to have good moral character (Royong vs. Oblena, 117 Phil. 865).
A lawyer may be disbarred for grossly immoral conduct, or by reason of his
conviction of a crime involving moral turpitude". A member of the bar should
have moral integrity in addition to professional probity.It is difficult to state
with precision and to fix an inflexible standard as to what is "grossly immoral
conduct" or to specify the moral delinquency and obliquity which render a
lawyer unworthy of continuing as a member of the bar. The rule implies that
what appears to be unconventional behavior to the straight-laced may not be
the immoral conduct that warrants disbarment.
This Court found that respondent's refusal to marry the complainant was
not so corrupt nor unprincipled as to warrant disbarment. (See Montana vs.
Ruado, Administrative Case No. 507, February 24, 1975, 62 SCRA 382; Reyes
vs. Wong, Administrative Case No. 547, January 29, 1975, 63 SCRA 667,
Viojan vs. Duran, 114 Phil. 322; Abaigar vs. Paz, Administrative Case No. 997,
September 10, 1979,93 SCRA 91).
Considering the facts of this case and the aforecited precedents, the complaint
for disbarment against the respondent is hereby dismissed.
In the case of Atty. Ecraela vs Atty. Pangalangan, the Supreme Court
ruled the moral delinquency that affects the fitness of a member of the bar to
continue as such includes conduct that outrages the generally accepted moral
standards of the community, conduct for instance, which makes 'a mockery of
the inviolable social institution of marriage." In various cases, the Court has
held that disbarment is warranted when a lawyer abandons his lawful wife and
maintains an illicit relationship with another woman who has borne him a
child. Furthermore, by displaying deplorable arrogance by making a mockery
out of the institution of marriage, and taking advantage of his legal skills by

attacking the Petition through technicalities and refusing to participate in the

proceedings. His actions showed that he lacked the degree of morality required
of him as a member of the bar, thus warranting the penalty of disbarment.
WHEREFORE, in consideration of the foregoing, the Court resolves to
ADOPT the resolution of the IBP Board of Governors approving and adopting,
with modification, the Report and Recommendation of the Investigating
Commissioner. Accordingly, respondent Atty. Ian Raymond A. Pangalangan is
found GUILTY of gross immorality and of violating Section 2 of A1iicle XV of the
1987 Constitution, Canon 1 and Rule 1.01, Canon 7 and Rule 7.03, and Rule
10.01 of Canon 10 of the Code of Professional Responsibility, and the Lawyer's
Oath and is hereby DISBARRED from the practice of law.
In the case of De Los Reyes vs. Atty. Aznar, it was highly immoral of
respondent, a married man with children, to have taken advantage of his
position as chairman of the college of medicine in asking complainant, a
student in said college, to go with him to Manila where he had carnal
knowledge of her under the threat that she would flunk in all her subjects in
case she refused.
WHEREFORE, respondent Jose B. Aznar is hereby DISBARRED and his
name is ordered stricken off from the Roll of Attorneys.
In the case of Guevarra vs Atty. Eala, the Supreme Court ruled, while
it has been held in disbarment cases that the mere fact of sexual relations
between two unmarriedadults is not sufficient to warrant administrative
sanction for such illicit behavior, it is not so with respect tobetrayals of the
marital vow of fidelity. Even if not all forms of extra-marital relations are
punishable under penal law, sexual relations outside marriage is considered
disgraceful and immoral as it manifestsdeliberate disregard of the sanctity of
marriage and the marital vows protected by the Constitution and affirmed by
our laws
WHEREFORE, the petition is GRANTED. Resolution No. XVII-2006-06
passed on January 28, 2006 by the Board of Governors of the Integrated Bar of
the Philippines is ANNULLED and SET ASIDE.
Respondent, Atty. Jose Emmanuel M. Eala, is 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.
From the above cases, the supreme court laid common ground on the
conduct of lawyers and the fulfilment of the Code of Professional Responsibility
and the Oath to which they would or have sworn to in the practice of their
profession. With morality and conduct being a requirment of the admission to
bar, this is also true to the continued requirment of membership to the bar. the

the above cases, cited that the respondents behaviour should be in conformity
to the Code and Oath mentioned. And that these mentiond are binding to,
qualified candidates in the admission to the Bar (Figuroa vs Barranco), Newly
Admitted to the Bar (Arciga vs Maniwag), and the continued admission to the
Bar (Atty. Ecraela vs Atty. Pangalangan, De Los Reyes vs. Atty. Aznar,
Guevarra vs Atty. Eala).
Immoral conduct which was defined in the Arciga vs Maniwag as
That conduct which is willful, flagrant , or shameless and which shows a
moral indifference to the opinion of the good expectable members of the
community. With respect to these cases, The issues of morality which factors
the admission to the bar, rose when the respondents had questionable
behaviours towards the opposite sex, to which they placed in jeopardy the
profession they have to uphold. it is also noteworthy to cite that marriage is an
integral part of each cases that would determine the gravity of the gross
imorality.
The following also constitutes immoral gross conduct that would be
grounds for ceasation to or hindrance to be admitted to the bar.
A. Illicit relations
B. Chronic womanizing
C. Abuse of authority as an educator
D. Unscrupolus acts
E. Violations of marriage vows
These acts or behaviour tends to embody nonconformity of the code of
professional responsibilty and the oath sworn to by each lawyers.
Nevertheless, in these questions of morality for their admission to the
baror continued membership to the bar, the court provided options to repute
the complaints against them. De Los Reyes vs. Atty. Aznar the court cited
that it is therefore the duty of the lawyer whenever his moral character is put
to issue, to satisfy the court that he is fit and proper a person to enjoy
continued membership to the bar.
In conclusion, the profession of lawyering is one so delicate that it should
be affirmed by confromity to The Code of Professional Responsibility and the
Oath to be Sworn to. Morality and Behaviour should play big a part of this
conformity to which ceasation of good moral conduct tends to equate
termination of the previlages of membership or hindrance thereof to the bar.