Case Digest (B.M. No. 712)
Facts:
In B.M. No. 712, a petition was filed before the Supreme Court En Banc by Al C. Argosino, a successful 1993 Bar examinee, seeking admission to the practice of law and the taking of the attorney’s oath of office. On February 4, 1992, the Regional Trial Court of Quezon City, Branch 101, criminally charged Argosino and thirteen co-accused with homicide arising from the September 8, 1991 hazing death of Raul Camaligan. Through plea bargaining, all fourteen pleaded guilty to homicide through reckless imprudence, and on February 11, 1993, received sentences ranging from two years, four months and one day to four years. Eleven days later, they applied for probation; on June 18, 1993, Branch 101 granted Argosino a two-year probationary period. On July 13, 1993, Argosino petitioned to take the 1993 Bar Examinations, voluntarily disclosing his conviction and probation status. By En Banc Resolution dated August 14, 1993, he was allowed to sit for the bar and subsequently passed. He was nevCase Digest (B.M. No. 712)
Facts:
- Criminal proceedings and incident
- On 4 February 1992, a criminal information was filed in RTC Quezon City, Branch 101, charging Al C. Argosino and thirteen others with homicide in connection with the death of Raul Camaligan on 8 September 1991.
- The death resulted from severe physical injuries inflicted during “hazing” rites as part of a university fraternity initiation.
- Plea bargaining and conviction
- Argosino and his co-accused entered into plea bargaining, pleading guilty to homicide through reckless imprudence. The trial court accepted this plea.
- By judgment dated 11 February 1993, each accused was sentenced to imprisonment ranging from two years, four months, and one day to four years.
- Probation and Bar examination application
- On 22 February 1993, the fourteen accused filed applications for probation; probation was granted on 18 June 1993 for two years, commencing upon initial report to a probation officer.
- On 13 July 1993, Argosino petitioned for permission to take the 1993 Bar Examinations, disclosing his conviction and probation status; the Court en banc allowed him to sit for the exams on 14 August 1993.
- Bar performance and petition for admission
- Argosino passed the 1993 Bar Examinations but was not permitted to take the attorney’s oath.
- On 15 April 1994, he petitioned for admission to the bar and for oath-taking, averring that Judge Santiago terminated his probation on 11 April 1994.
- Subsequent motions and moral character requirement
- Argosino filed three motions for early resolution of his admission petition.
- The Court emphasized that admission to the bar is a privilege contingent upon proof of good moral character, requiring fresh evidence post-conviction and post-probation.
Issues:
- Whether Al C. Argosino, despite his conviction and probation for homicide through reckless imprudence, may be admitted to the bar and take the attorney’s oath.
- Whether Argosino has sufficiently demonstrated the requisite good moral character at the time of his application for admission to the practice of law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)