Title
Paar vs. Borromeo
Case
G.R. No. L-1582
Decision Date
Oct 10, 1947
Teofilo Paar, charged with treason, sought non-lawyer defense assistance in Manila; court denied, citing bar representation requirement under Rules 112 and 127.

Case Summary (G.R. No. 192398)

Legal Framework

The relevant provisions are found in the Rules of Court, specifically Sections 3 and 4 of Rule 112, as well as Sections 29 and 31 of Rule 127. These rules delineate the right of a defendant to legal representation and the criteria for appointing counsel, particularly in cases involving parties who are unable to afford legal services.

Legal Representation Rights

According to Rule 112, Section 3 imposes an obligation on the court to inform defendants of their right to legal counsel prior to arraignment. Should the defendant express a desire for legal representation but lacks the means to hire an attorney, the court is required to appoint an attorney de oficio. This appointment is mandatory unless the court finds sufficient cause to excuse the attorney from providing service.

Appointment of Non-Bar Members

Rule 112, Section 4 allows the court, at its discretion, to admit or assign a person of good reputation and ability to assist a defendant in areas where there are no available licensed attorneys. However, this provision is only applicable in provinces with a shortage of bar members, which does not apply to Manila where multiple attorneys are accessible.

Assignment of Free Legal Aid

Rule 127, Section 29 underscores the court's ability to assign an attorney to provide free legal aid to indigent parties, provided that an investigation confirms their destitution and the necessity for legal counsel. It is the attorney's duty to represent the party unless excused by the court for adequate reasons.

Conduct of Litigation

Rule 127, Section 31 specifies that individuals may conduct their litigation personally, with aid from a friend or appointed agent, or through an attorney, depending on the court type. However, in courts other than those of justices of the peace, representation must involve a duly authorized member of the bar.

Court's Conclusion

The court concluded that in Manila, where a sufficient number of bar member

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