Title
IN RE: Purisima
Case
B.M. No. 979, 986
Decision Date
Dec 10, 2002
Mark Anthony Purisima, disqualified for failing to submit pre-bar review certification and alleged dishonesty, was later allowed to take the Lawyer’s Oath after proving clerical error and substantial compliance.

Case Summary (B.M. No. 979, 986)

Background and Issue at Hand

Petitioner was permitted to take the Bar Examinations under the condition that he would submit a certificate of completion of a pre-bar review course within sixty days from the last day of the examinations. After passing the examinations, he was disqualified by a resolution dated April 13, 2000, by the Supreme Court, citing two primary grounds: (1) his failure to provide the required certification under oath, and (2) an act of dishonesty concerning his attendance at the pre-bar review course.

Initial Disqualification

The court's disqualification noted that Purisima had falsely stated that he attended the pre-bar review course at the Philippine Law School when, in fact, the institution had not offered such a course since 1967. The absence of the required certificate and the alleged dishonesty concerning where he completed his review course led to the court's decision to nullify his examination results.

Petitioner’s Motion for Reconsideration

Following the court's decision, Purisima filed a motion for reconsideration, which was denied. Subsequently, his father, retired Judge Amante P. Purisima, submitted a petition to reopen Bar Matter 986, but this was not acted upon by the court.

Clarification and Explanation

In July 2002, Purisima submitted a motion seeking to explain the discrepancies in his original petition. He argued that the mention of the Philippine Law School as his review institution was a clerical error made by a friend who notarized and filed the petition on his behalf. To support his claim, he provided various documents including certifications, receipts, and affidavits from classmates and faculty attesting to his enrollment and attendance at the University of Santo Tomas, where he completed his pre-bar review course.

Hearings and Recommendations

The Office of the Bar Confidant conducted a summary hearing that elucidated the authenticity of the documents presented by Purisima. The Office recommended that he should be given the benefit of the doubt, citing previous similar cases where candidates had been allowed to take their oaths despite comparable issues. The recommendation also highlighted the need for compassion in the face of apparent oversight rather than malicious intent.

Court's Final Decision

In its final ruling, the court acknowledged Purisima's explanations and the supporting documents, accepting that while there were procedur

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