Title
IN RE: Admission to the Bar and Oath-Taking of Successful Bar Applicant Argosino
Case
B.M. No. 712
Decision Date
Jul 13, 1995
Al C. Argosino, convicted in a fatal hazing incident, sought Bar admission. The Supreme Court denied immediate admission, citing lack of good moral character but allowed future proof of rehabilitation.

Case Summary (B.M. No. 712)

Procedural Background

  • February 4, 1992: Criminal information for homicide filed against Argosino and 13 co-accused.
  • September 8, 1991: Death of Camaligan due to severe injuries inflicted during hazing rites.
  • Plea Bargain: All accused plead guilty to homicide through reckless imprudence.
  • February 11, 1993: RTC conviction and sentence of 2 years, 4 months, 1 day to 4 years’ imprisonment.
  • June 18, 1993: Probation granted for two years, effective upon reporting to probation officer.
  • July 13, 1993: Petition to take the 1993 Bar Examinations filed; permission granted August 14, 1993.
  • April 11, 1994: Probation terminated by the RTC.
  • April 15, 1994: Petition filed for admission to the bar and oath-taking.

Applicable Law

  • 1987 Philippine Constitution governs admission to the practice of law.
  • Practice of law is a privilege, not a right, conditioned upon citizenship, academic qualifications, and good moral character.

Good Moral Character Requirement

  • Lawyers are officers of the court entrusted with client confidences, property, and lives.
  • Jurisprudence mandates an “upright character” that goes beyond absence of wrongdoing (In re Farmer; In re Kaufman; In re Keenan; Re Rouss; Cobb v. Judge of Superior Court).
  • Character inquiry for admission is broader than disbarment proceedings (Re Stepsay; Re Wells).
  • Public confidence in the legal system depends on a stringent moral standard for bar applicants.

Court’s Analysis on Moral Character

  • The intentional infliction of fatal injuries on a vulnerable fraternity newcomer demonstrates a grave breach of moral duties.
  • Argosino’s conduct during hazing reveals character flaws incompatible with the responsibilities of a lawyer.
  • Expiration or termination of probation does not automatically rehabilitate one’s moral standing for bar admission.
  • Good moral character must be established both at the bar exam stage and at the time of oath-taking.

Directives and Requirements

  • Argosino must submit evidence of moral rehabilitation, including sworn certifications from reputable community members who have
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