G.R. No. 199650 - J Plus Asia Development Corp. vs. Utility Assurance Corp.

In a decision promulgated on September 30, 1955, the Court of First Instance of Negros Oriental found petitioner Quinciano D. Vailoces guilty of falsification of a public document.
The offense involved his acknowledgment, in his capacity as a member of the bar and notary public, of executing a document purported to be the last will and testament of Tarcila Visitacion de Jesus, which was later challenged and found to be a forgery.
He was penalized under Article 171 of the Revised Penal Code with an indeterminate sentence ranging from 2 years, 4 months and 1 day to 8 years and 1 day of prision mayor, including accessory penalties, fines, and costs.

Following his criminal conviction, disbarment proceedings were instituted by Ledesma de Jesus-Paras, the complainant in the criminal case.
These proceedings culminated in his disbarment on April 12, 1961.
On December 27, 1967, the President of the Philippines granted him an "absolute and unconditional pardon" and restored him "to full civil and political rights."

Since August 23, 1968, petitioner repeatedly sought readmission to the practice of law.
His initial petition was denied by the Court on August 30, 1968, and a subsequent petition on February 27, 1970, was deferred pending the integration of the bar.
On December 12, 1977, he filed another petition for reinstatement, attaching various documents evidencing endorsements of his character.

Resolution of the Negros Oriental Bar Association endorsed his petition with the signature of 78 members.
A certificate from the mayor of Bindoy, Negros Oriental attested to his exemplary moral character and law-abiding lifestyle.
Certification from Governor William B. Villegas affirmed his straight and respectable conduct and active participation in civic and social undertakings.
A certification from Dean Eduardo G. Flores of the College of Law, Silliman University, along with endorsements from Atty. Alexander G. Amor, a former president of the Negros Oriental Chapter of the Integrated Bar of the Philippines.
Clearance certificates from Judge Romeo R. Solis and City Fiscal Pablo E. Cabahug corroborated that petitioner's conduct post-incarceration had never involved any crime of moral turpitude.

Opposition to his reinstatement came from Ledesma de Jesus-Paras and a telegram from barangay captain Nicanor Vailoces, citing non-reformation, immoral conduct, and improper pretensions of legal practice.
The Integrated Bar of the Philippines, via its then-president Atty. Marcelo B. Fernan, initially endorsed petitioner's reinstatement and later requested his comments on the oppositions.
In his comment, petitioner addressed the subjective allegations, notably rebuffing charges linked to immorality (including maintaining a "querida") and gambling.
Controversial inconsistencies were noted, such as the conflicting positions of municipal officials like Mayor Jesus A. Mana-ay, who was previously supportive of petitioner's character but later appeared in opposition by endorsing a petition against his reinstatement.

Following the submission of oppositions, the Integrated Bar referred the matter to the Solicitor General for further investigation.
On August 4, 1982, the Solicitor General’s report recommended that petitioner be reinstated upon taking his oath anew.
The report emphasized that although the plenary pardon did not in itself warrant reinstatement, sufficient evidence of reformation and restoration of good moral character had been provided.

Whether the petitioner, despite his prior conviction and disbarment, has sufficiently demonstrated moral reformation and rehabilitation to justify readmission to the practice of law.
Whether the evidence of good moral character and endorsements from reputable professionals and public officials can outweigh the gravity of his past offense and subsequent disbarment.
Whether the opposition, comprising subjective allegations of non-reformation, immorality, and improper conduct, meets the specificity required to undermine the petitioner’s claim for reinstatement.
Whether the procedural requirements and evidentiary standards for readmission to the bar have been satisfied in this particular case.