A.M. No. 126, December 29, 1980
In re: ATTY. TRANQUILINO ROVERO, respondent.

FACTS

On October 24, 1952, the Supreme Court ordered the disbarment of Atty. Tranquilino Rovero after he was convicted of smuggling under the Revised Administrative Code and sentenced to pay a fine. Subsequently, Rovero filed petitions for reinstatement in 1956 and 1958, both of which were denied by the Court despite his claims of remorse and the grant of an absolute pardon by then President Ramon Magsaysay.
In this third petition, filed decades after his disbarment, the now 71-year-old respondent humbly implores the Court for reinstatement to the legal profession before the end of his life. He submits extensive evidence of his post-disbarment life to demonstrate his rehabilitation and current moral fitness.

ISSUE

Whether Atty. Tranquilino Rovero has sufficiently demonstrated moral rehabilitation and fitness to warrant his reinstatement to the practice of law.

RULING

Yes, the Supreme Court granted the petition and ordered Rovero’s reinstatement. The legal logic for reinstatement hinges on two principal grounds: demonstrated moral rehabilitation and the legal effect of an absolute pardon. The Court reiterated that for reinstatement, a petitioner must prove present good moral character, like any bar applicant. The record established that for over 28 years since his disbarment, Rovero lived an honorable and productive life. He held significant positions of public trust, such as Secretary of the Provincial Board of Aklan, and leadership roles in civic, educational, and business organizations like the Quezon City Central Lions Club and the Rural Bank of Hermosa. Numerous testimonials, including from the local bar association and his parish priest, attested to his good standing and charitable contributions in his community.
Crucially, the Court emphasized the effect of the absolute pardon granted to him. Following the precedent in In re Lontok, an absolute pardon blots out the guilt of the offense and removes all legal disabilities arising from the conviction. It restores the offender’s civil rights and, in the eyes of the law, treats him as innocent. While a pardon does not automatically entitle one to reinstatement, it is a significant factor when combined with clear evidence of reformation. The Court concluded that the lengthy period of discipline, his exemplary conduct, and the pardon collectively proved Rovero’s moral rehabilitation. He had been sufficiently punished and was now a fit and proper person to resume law practice.