G.R. No. 185597 - Reyes vs. Doctolero

On May 29, 1959, the Court disbarred respondent Atty. Carlos C. Rusiana for committing acts of misconduct as a notary public and for exhibiting a frame of mind unworthy of a member of the legal profession.
Respondent was admitted to the Philippine Bar on January 21, 1955, and his disbarment was based on ethical and professional misconduct issues.

After his disbarment, respondent intermittently filed petitions for re-admission to the bar.
These petitions were supported by resolutions and certifications from members of the Bench and Bar, labor unions, newspaper editors and reporters, as well as from various professional and civic organizations in Cebu, all attesting to his good conduct and moral character over the intervening years.
Earlier petitions for reinstatement were denied by the Court.

Respondent filed a verified petition for reinstatement, presenting proofs of his honesty, integrity, and moral reformation.
Submitted documents included:

Clearances from the City Courts and Court of First Instance of Cebu.
Clearance from the Police Department of Cebu City.
Testimonials on his character from fiscals, lawyers, and judges of both the City Courts and the Court of First Instance.
Resolutions from various groups such as the Cebu Lions Club, Sto. Rosario Council No. 5508 of the Knights of Columbus, the Bar Association of Cebu, and the Cebu Lawyers League, Inc.

The Court acknowledged that respondent had sufficiently undergone punishment by his disbarment and maintained exemplary conduct in the ensuing years.
Despite this, due to the numerous changes in the law since 1959, the Court required respondent to offer a guarantee of his ability to adequately serve prospective clients.
The mandatory condition imposed was for respondent to:

Enroll in and pass regular fourth-year review classes in a recognized law school.
Submit sworn certificates from the individual professors confirming his regular attendance and successful completion of his subjects under the same conditions as ordinary students.
Upon compliance, take anew the lawyer’s oath and sign the Roll of Attorneys maintained by the Clerk of the Supreme Court.

Follow-up certifications from the Registrar and the Dean of Gullas Law School at the University of the Visayas, dated February 25, 1974, confirmed that the respondent had indeed complied with the enrollment and examination requirements.

In view of the complete compliance with the Court’s imposed conditions, respondent Carlos C. Rusiana was allowed to retake the lawyer’s oath and sign the Roll of Attorneys after settling the requisite fees.

Whether the respondent had sufficiently reformed his character and conduct since his disbarment.
Whether the evidence of good moral character and testimonials provided were adequate to prove rehabilitation.

Whether the additional requirement for the respondent to enroll in and pass fourth-year review classes was a justifiable condition to guarantee his current competence and updated legal knowledge in light of changes in the law.
Whether compliance with these conditions should lead to the respondent’s restoration to the legal profession.

Whether reinstating a previously disbarred attorney under such conditions serves the public interest and maintains the integrity of the legal profession, which is considered an office of trust.